(Disclosure according to SFDR -EU 2019/2088-) 10.03.2021

Ι. Scope

The present Remuneration Policy of DECA Investments AIFM (“DECA”) sets the framework and defines the principles, according to which DECA ought to operate as regards remuneration of personnel (the “Policy”). The Policy incorporates the basic principles of the regulatory framework in force, including Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (”SFDR”).

Overall, the Policy:

  • promotes sound and effective risk management in accordance with DECA’s risk management framework, including with respect to sustainability risks.
  • aims to discourage risk-taking which is inconsistent with the risk profiles, principles, rules, internal procedures, constitutional documents, and management regulations of the alternative investment funds that DECA manages (“AIFs”, and each of them an “AIF”).
  • is in line with the business strategy, objectives, values and interests of the AIFs or their investors.
  • includes measures to avoid conflicts of interest.
  • encourages adherence to sound environmental, social and governance (“ESG”) principles.
  • is aligned with DECA’s ESG Policy and ensures that the structure of the remuneration does not encourage risk-taking with respect to sustainability risks.
  • encourages the company to provide a good sustainable workplace.
  • encourages responsible behavior that supports sustainable business and investments.
  • supports a diverse working environment.
  • meets relevant EU and national regulatory (including SFDR) requirements.

The Policy is based on DECA’s risk management framework which takes into account all relevant considerations, including ESG considerations. DECA’s remuneration policy is designed not to encourage risk-taking (including with regard to sustainability risks) which is inconsistent with the risk profiles, principles, internal procedures, constitutional documents and management regulations of the AIFs under management.

DECA’s remuneration structure takes the form of:

  • Fixed compensation. Base salaries provide a competitive level of fixed compensation in the form of cash paid on a monthly basis, reflecting each employee’s position, experience and qualifications.
  • Variable compensation. A substantial portion of the variable remuneration (for senior management) is deferred over a period which is appropriate to the life cycle of the AIF concerned and is correctly aligned with the nature of the undertaken risks (including sustainability risks).

The Remuneration Policy, according to the principal of proportionality, is appropriate to the size, internal organization and the nature, scope, and complexity of DECA activities.  

DECA holds the right to update this Policy whenever necessary and on time due without prior notice.