UCITS Remuneration Policy Statement

Application

This UCITS Remuneration Policy Statement applies to Trillium. The Firm is a sub‐investment manager located in the United States of America, which is contracted to carry out investment management activities in relation to the UCITS funds, which are subject to the remuneration rules in the EU’s UCITS Directive (the "UCITS Remuneration Code"). As a delegated portfolio manager of UCITS funds, the Firm is required: (a) to have a remuneration policy in respect of the UCITS funds it manages, and (b) to operate remuneration policies in respect of those funds which do not circumvent the UCITS Remuneration Code.

General

The Firm acknowledges the following general principles in respect of the UCITS Funds:

  • remuneration policies, procedures, and practices (collectively referred to as the “remuneration policies”) should be consistent with and promote sound and effective risk management and not encourage risk‐taking that exceeds the level of tolerated risk of the UCITS Funds as set forth in the applicable investment management agreement, prospectuses;
  • remuneration policies should be in line with the business strategy, objectives, values, and longterm interests of the Firm, the UCITS it manages, and investors in those UCITS Funds and should include measures to avoid conflicts of interest; and
  • the structure of an employee’s Remuneration should be consistent with and promote effective risk management.

The firms remuneration practices are consistent with the general principles set out above, in relation to material risk takers of the Firm (“MRT’s”) to the extent their activities relate to the UCITS Funds.

The application of the rules in the UCITS Remuneration Code is subject to the proportionality rule in Article 14(b)(1) of the UCITS Directive (the “UCITS Firm Proportionality Rule”) which provides that a UCITS management company must comply in a way and to the extent that is appropriate to its size, internal organization, and the nature, scope, and complexity of its activities. In accordance with the European Securities and Markets Authority’s (ESMA) guidance on the application of the UCITS Remuneration Code (the “UCITS Guidance”), the Firm is permitted to disapply certain principles contained within the UCITS Remuneration Code.

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