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 remuneration 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 remuneration 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 benefits, such as sickness, accident and pension insurance, but these are not variable remuneration components.

Creutz & Partners does not pay guaranteed variable remuneration components. All variable remuneration 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 remuneration components 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) RENUMERATION COMPONENTS DEPENDENT ON THE IMPLEMENTATION AND/OR ACHIEVEMENT OF SUSTAINABILITY OBJECTIVES

Creutz & Partners considers sustainability risks within the meaning of Regulation (EU) 2019/2088 as part of its investment decision‐making process in its discretionary asset management activities as well as with the management of the C&P Funds.

Creutz & Partners does however not define any specific sustainability objectives that would have to be observed and/or achieved by the company and/or the individual employees within the framework of the aforementioned investment activities (for example, the definition of a certain proportion of sustainable investments in discretionary asset management and in the management of the C&P Funds).

Accordingly, Creutz & Partners does not pay any variable remuneration components to its employees - in particular the members of the investment committees or the control functions - that are dependent on the observance and/or achievement of sustainability objectives.

G) 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.

As a conservative asset manager, Creutz & Partners pursues a long-term approach and generally invests for its customers only in securities of issuers that meet high qualitative standards. As part of a fundamental analysis, environmental, social or governance factors ("ESG") and the sustainability risks that can be derived from them are also considered, as these can have an impact on the investment performance. However, Creutz & Partners does not explicitly promote environmental or social characteristics and does not offer any explicitly sustainability-related investment strategies. ESG factors and sustainability risks are appropriately considered in the overall context of all decision-making criteria regarding investments in the context of asset management.

Creutz & Partners integrates principal sustainability risks into its investment decision-making processes in order to achieve positive returns for the customers over the long term with the help of comprehensive risk management. In this regard, Creutz & Partners pays attention to a sustainable business model and appropriate corporate governance of the investments of the asset management, which allow the expectation of a long-term increase in the enterprise value due to entrepreneurial success. The securities of a company will only be considered as an investment for Creutz & Partners if the company generates high and secure returns in the long term and if it is not exposed to significant ESG risks.

For the evaluation of sustainability risks, company data on ESG factors and ratings derived from them can be a useful basis within the framework of the qualitative assessment of a company. Creutz & Partners uses company data on ESG indicators and/or ESG ratings from recognized and reliable data providers, as far as available, in its analysis and to identify and weight principal adverse sustainability impacts and indicators. However, ESC indicators and ESC ratings never replace the full analysis and evaluation of individual investments for their opportunities and risks through the members of the Creutz & Partners investment committees with their long-standing professional experience. The investment committees therefore do not apply ESG company data and ratings as strict exclusion criteria. Instead, ESG risk factors - like other influencing factors as well - are considered as part of a comprehensive investment and risk management process in order to achieve good risk-return characteristics and thereby generating sustainable, long-term returns for the customers of Creutz & Partners. This way, possible ESG conflicts are assessed and evaluated with regard to their influence on the security and on the level of return potential of the investments. With regard to possible effects on investment performance, sustainability risks are thus considered as part of the general valuation risk. In this manner, the investment committees decide on a case-by-case basis, based on a comprehensive analysis process, as to whether companies stand out positively or negatively when ESG factors are considered and whether this justifies an investment of Creutz & Partners. The respective decision-making basis is elaborated in the meetings of the investment committees and documented in detailed minutes. This investment approach is based on an understanding of the long-term and sustainable quality of an investment for the customers of Creutz & Partners.

“Sustainability Risks” mean environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the investment performance.

Sustainability risks may not only constitute a risk themselves, but may also have a significant impact on other risks, thus increasing market risks, operational risks, liquidity risks or counterparty risks. Sustainability risks can equally have an impact on the value of the investments in short, medium or long term.

Creutz & Partners integrates principal sustainability risks into its investment decision-making process in order to achieve positive returns for the customers over the long term with the help of comprehensive risk management. ESG risk factors - like other influencing factors as well - are considered as part of a comprehensive investment and risk management process in order to achieve good risk-return characteristics and thereby generating sustainable, long-term returns for the customers of Creutz & Partners.

Assessing sustainability risks is complex and can be based on factors such as environmental, social or governance data, which can be difficult to obtain and may be incomplete, estimated, outdated or inaccurate for other reasons. Even if they are identified, uncertainty remains as to whether the data can be properly obtained and comparably assessed.

With regard to sustainability impacts and indicators, Creutz & Partners therefore does currently not follow any code of responsible corporate governance or internationally recognized standards for due diligence or reporting.

Since Creutz & Partners currently does not explicitly promote environmental or social characteristics and does also not offer investment strategies that are explicitly sustainability-related, Creutz & Partners’ investment decision-making processes are currently not aligned with the objectives of the Paris Agreement.

The exercise of shareholder rights can help companies to increasingly pay attention to sustainability risks and to make their business model more sustainable and develop a corresponding corporate culture and management.

As management company of the C&P Funds, Creutz & Partners will, pursuant to its participation policy, only exercise shareholder and voting rights in a portfolio company if the share in the company held by the C&P Funds represent more than 5% of the funds’ assets and Creutz & Partners can assume that the voting result can be significantly influenced by participating in the voting proceeding. Creutz & Partners assumes that this is generally the case if the C&P Funds holds a total of more than 3% of the voting shares of the respective company. Particularly with regard to the observance and pursuit of sustainability goals at the portfolio companies, participation in the voting process only takes place if Creutz & Partners can assume that the company intends to make a significant change in its strategy or if decisions are to be made that (could) have a negative impact on the sustainability of the company and/or (could) increase existing sustainability risks.

In the context of the discretionary asset management, Creutz & Partners generally does not exercise any shareholder rights in then name and for the account of its customers. The customers themselves own the assets held in custody at their depository bank (Creutz & Partners only receives an asset management mandate) and can therefore directly exercise their shareholder rights in the portfolio companies themselves or through their depository bank.

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