Remuneration Policy
Remuneration Policy for EPIC Investment Partners (Ireland) Limited
EPIC Investment Partners (Ireland) Limited (the “Company”) has designed and implements a remuneration policy which is consistent with and promotes sound and effective risk management by having a business model which by its nature does not promote excessive risk taking. The Company’s remuneration policy is consistent its business strategy, objectives, values and interests and includes measures to avoid conflicts of interest.
The Company’s remuneration policy applies to those categories of staff, including senior management, risk takers, control functions and any employee receiving total remuneration.
In line with the provisions of the UCITS Directive as may be amended from time to time, the Company applies its remuneration policy and practices in a way and to the extent that is proportionate to its size, its internal organisation and the nature, scope and complexity of its activities.
Where the Company delegates investment management functions in respect of any Fund, it will, in accordance with the requirements of the ESMA Guidelines on Sound Remuneration Policies under the UCITS Directive (ESMA/2016/575), ensure that:
(a) the entities to which investment management activities have been delegated are subject to regulatory requirements on remuneration that are equally as effective as those applicable under the ESMA Remuneration Guidelines; or
(b) appropriate contractual arrangements are put in place to ensure that there is no circumvention of the remuneration rules set out in the ESMA Remuneration Guidelines.
(c) Integration of Sustainability Risks in Investment Decision-Making
EPIC Investment Partners (Ireland) Limited ("EPIC") integrates sustainability risks into its investment decision-making process as part of its responsibilities as an authorised Alternative Investment Fund Manager ("AIFM") and UCITS Management Company.
Prior to the appointment of any delegated investment manager, EPIC undertakes appropriate due diligence to assess, amongst other matters, the delegate's investment process, risk management framework, governance arrangements and approach to the integration of environmental, social and governance ("ESG") considerations and sustainability risks. This assessment forms part of EPIC's delegate selection and approval process.
Following appointment, EPIC maintains ongoing oversight of delegated investment managers through its Investment Management oversight framework. The Designated Person for Investment Management reviews the implementation of each fund's investment objectives, investment policy, investment restrictions and, where applicable, the integration of sustainability risks and ESG considerations into the investment process. Oversight activities are supported by regular reporting from delegated investment managers and are reported to the Board of Directors.
The manner in which sustainability risks are integrated into investment decisions may vary depending on the investment strategy, asset class and regulatory classification of each fund. Where a fund promotes environmental or social characteristics under Article 8 of the Sustainable Finance Disclosure Regulation ("SFDR"), or has sustainable investment as its objective under Article 9 SFDR, EPIC oversees compliance with the applicable sustainability commitments and disclosure obligations.
EPIC reviews its investment oversight framework and associated policies on a periodic basis to ensure continued compliance with applicable regulatory requirements and evolving market best practice.