Legal / Imprint

1. PRELIMINARY NOTE

By applying a customer complaint management policy, Creutz & Partners aims to achieve the best possible result in the interest of the customer. The customers’ interest has always been a foremost priority for Creutz & Partners. All customer complaints are taken seriously and are going to be treated with due regard to an efficient and transparent procedure.
The following provisions are a summary of Creutz & Partners’ customer complaint management policy and should allow our customers to gain insight into the procedure of handling customer complaints.

2. SUBMISSION OF CUSTOMER COMPLAINTS

Any customer complaint should be sent in writing to the customer complaint manager in one of the languages offered by Creutz & Partners, namely in German, French, Dutch or English at the following address:

Creutz & Partners Global Asset Management S.A.
Customer Complaints Manager
18, Duarrefstrooss
L-9944 Beiler

3. PROCEDURE

The goal of the customer complaint manager is to identify immediately a satisfying solution for the customer. In his response to the complaint, the complaint manager informs the customer of this solution.
Should this not be possible within the first two working days after the date Creutz & Partners has received the complaint, the customer will be notified via an intermediate reply explaining the reasons for the delay in giving a definitive answer.
If the definitive answer to the customer complaint has not been communicated within ten working days after submission of the intermediate reply, the customer will receive a further notification clarifying the matter.
The customer can send an informal notification to Creutz & Partners, if he/she does not agree with the results and the measures taken by the customer complaint manager and stated in the definitive reply to the customer’s complaint.
In case the customer does not agree with the treatment or with the proposed solution concerning his/her complaint after receipt of the definitive answer, he/she can initiate an out-of-court complaint resolution procedure before the CSSF »Commission de Surveillance du Secteur Financier«, which is the supervisory authority of Creutz & Partners, about which Creutz & Partners will provide the customer with separate information.

1. PRELIMINARY NOTE

By applying a customer complaint management policy, Creutz & Partners aims to achieve the best possible result in the interest of the investor. The investors’ interest has always been a foremost priority for Creutz & Partners. All investor complaints are taken seriously and are going to be treated with due regard to an efficient and transparent procedure.
The following provisions are a summary of Creutz & Partners’ customer complaint management policy and should allow the investors of the C&P Funds to gain insight into the procedure of handling investor complaints.

2. SUBMISSION OF INVESTOR COMPLAINTS

Any investor complaint regarding the management of the C&P Funds should be sent in writing to the customer complaint manager in one of the languages offered by Creutz & Partners, namely in German, French, Dutch or English at the following address:

Creutz & Partners Global Asset Management S.A.
Customer Complaints Manager
18, Duarrefstrooss
L-9944 Beiler

3. PROCEDURE

The goal of the customer complaint manager is to identify immediately a satisfying solution for the investor. In his response to the complaint, the complaint manager informs the investor of this solution.
Should this not be possible within the first two working days after the date Creutz & Partners has received the complaint, the investor will be notified via an intermediate reply explaining the reasons for the delay in giving a definitive answer.
If the definitive answer to the investor complaint has not been communicated within ten working days after submission of the inter- mediate reply, the investor will receive a further notification clarifying the matter.
The investor can send an informal notification to Creutz & Partners, if he/she does not agree with the results and the measures taken by the customer complaint manager and stated in the definitive reply to the investor’s complaint.
In case the investor does not agree with the treatment or with the proposed solution concerning his/her complaint after receipt of the definitive answer, he/she can initiate an out-of-court complaint resolution procedure before the CSSF »Commission de Surveillance du Secteur Financier«, which is the supervisory authority of Creutz & Partners, about which Creutz & Partners will provide the investor with separate information.

The following information should provide clients of Creutz & Partners as well as investors of the C&P Funds with details about the remuneration policy of Creutz & Partners

A paper version of this information can be requested from Creutz & Partners free of charge.

A) BACKGROUND

Creutz & Partners has a remuneration policy that regulates the remuneration of certain employees in detail. The remuneration policy has been in place for many years and was adapted in the wake of EU Directive 2014/91 (UCITS V) to comply with Articles 111bis and 111ter of the Luxembourg Law of 17 December 2010 on Undertakings for Collective Investment. The remuneration policy further complies with the ESMA guidelines 2016/575 and the relevant regulatory requirements in Luxembourg.

B) OBJECTIVES OF THE REMUNERATION POLICY

This remuneration policy is intended to set up a remuneration structure at Creutz & Partners which can be reconciled with sound and effective risk management and which promotes this.

It should ensure that the remuneration structure does not encourage the taking of risks that cannot be reconciled with the risk profiles, contract conditions or statutes of the C&P Fund managed by Creutz & Partners, nor that it hinders the management company from dutifully acting in the best interest of the C&P Fund and its investors.

C) EMPLOYEES THAT ARE AFFECTED

Creutz & Partners has identified the employees to whom its remuneration policy applies in accordance with the provisions of the above-mentioned directive.

These are

- The members of the board of directors;
- The members of the company’s executive management;
- The fund managers;
- The employees in the risk management, compliance and internal audit departments;
- The relationship managers.

This includes all persons whose activities may materially influence the risk profile of Creutz & Partners or the managed C&P Funds or who, based on their remuneration in accordance with the EU Directive 2014/91, fall under the scope of the remuneration policy.

Moreover, Creutz & Partners also applies the fundamental principles of the remuneration policy to all other employees.

D) PRINCIPLE OF PROPORTIONALITY

Creutz & Partners applies the principle of proportionality embedded in EU Directive 2014/91 based on its size, its structure as well as the type of services that are performed and the business that is conducted. Accordingly, Creutz & Partners waives the payment of variable compensation components in the form of shares of the managed investment fund, the delayed or deferred payment of variable salary components and the setup of a remuneration committee.

E) COMPENSATION STRUCTURE AND COMPONENTS

Employees of Creutz & Partners in principle receive a fixed salary component that is sufficiently high to secure their livelihood and to enable them to perform an activity at Creutz & Partners that meets the needs of the clients and the investors of the C&P Funds.

In addition, employees of Creutz & Partners may receive variable compensation components. These relate to the level of the managed volume, the level of fees that were already received for completed performance periods or the amount of company profit.

Furthermore, employees of Creutz & Partners can receive additional salary components, such as sickness, accident and pension insurance, but these are not variable salary components.

Creutz & Partners does not pay guaranteed variable salary components. All variable salary components are subject to the possibility of recovery by the company if it subsequently emerges that the quantitative or qualitative conditions have not been met.

The quantitative and qualitative conditions for the payment of variable compensation are selected in such a way that they also aim to serve the interests of the clients of Creutz & Partners as well as of the investors of the C&P Funds, to effectively limit risk and to not encourage employees to follow any strategies that increase the risk for Creutz & Partners, for the C&P Funds and for the clients/ investors.

F) DECISION-MAKING STRUCTURE

The board of directors of Creutz & Partners decides on the structure of the remuneration policy. The chairman of the board of directors and the executive member of the board of directors decide on the payment of variable compensations. The member of the board of directors responsible for compliance and the compliance officer of Creutz & Partners shall inform the chairman of the board of directors if quantitative or qualitative obstacles do not allow the payment of variable compensation components.

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