Regulatory InformationIn accordance with regulations and our policy of transparency, Quamvest S.A. provides various documents that you will find below.
This procedure covers the obligations of Quamvest regarding potential client complaints and how they can be submitted by an investor or client.
Quamvest S.A. best execution rules are embedded within the larger scope of Quamvest’s duty to act in the best interest of the AIF’s investors.
Initially the best execution framework was delimited by the European Parliament.
Directive 2004/39/EC on Markets in Financial Instruments (MiFID). This directive sets a number of requirements for the investor’s protection standards that are designed to promote market efficiency and the best possible execution results for the investors.
MiFID best execution obligations require investment firms to take all reasonable steps to obtain, when executing orders on behalf of their clients, the best possible result, taking into account the executing factors (price, cost, speed, settlement, size, etc) or any other consideration relevant to the execution of the order.
On its turn, Commission Delegated Regulation 231/2013 (Regulation 231) governing the Alternative Investment Fund Managers industry, estates that the best interest of the AIFs investors must be protected at any time. For this, one of the protection measures that the Regulation 231 promotes is the best execution rule, applying the MiFID directive to the Alternative Investment Fund’s scope.
This remuneration policy (hereinafter the Policy) has the objective of defining and describing the principles and remuneration rules that apply to Quamvest’s employees. These guidelines are set by the Board of Directors of Quamvest S.A. following the recommendations of the Remuneration Committee (RC) of Quamvest S.A., the principles established in the remuneration policy of Quilvest Wealth Management (QWM) , and the key applicable regulations and 1 regulatory guidelines.
This Policy has been designed taken into account the business strategy, objectives, values and interests of the management company and portfolios it manages and of the investors in such portfolios, including the required measures to avoid conflicts of interest. The Policy seeks to promote a sound and effective risk management in a way that is consistent with the risk appetite of the Company and with the risk profiles of the portfolios it manages.
Liquidity Risk and Liquidity Management
Liquidity risk is the possibility that an organisation or investment vehicle will experience a decrease in value or losses due to its inability to secure the necessary liquid funds, or because it is forced to obtain them at far higher cost than under normal conditions, in order to run its operations and fulfil its obligations and commitments.
Additionally, a liquidity risk may refer to the lack of sufficient liquid funds to honour the obligations of an organisation or investment vehicle.
From an investment point of view, a liquidity risk can be market related —in terms of price impact and potential demands for additional guarantees—, linked to investor behaviour, derived from the investment implementation process, or connected to the operating requirements in the case of some particular investment structures.
Conflict of interest
Quamvest S.A. activities are ruled, among others, by the Law of 12 July 2013 on Alternative Investment Funds Managers (AIFM), the Law of 17 December 2010 on its chapter 15 regarding Management companies managing UCITS governed by Directive 2009/65/EC, and all the related regulations linked to these Laws at local and European level.
On the specific aspect covered by this document an additional level of regulations regarding conflict of interest is the Commission Delegated Regulation 231/2013 (the Regulation 231) that describes the type, policies, procedures, and monitoring of conflict of interest within the different activities of an AIFM, including the activities performed by delegation on behalf of the AIFM and the vehicles that it manages.
Additionally, CSSF Regulation 10-04, transposing European Directive 2010/43/EU, also refers to the organisational requirements regarding organisational requirements, conflicts of interest, conduct of business, risk management and content of the agreement between a depositary and a management company. Finally, CSSF circular 12/552 (as amended) requires that regulated entities establish a conflict of interest policy.
In the general context of the avoidance of Conflict of Interest, European regulations establish that asset managers “must develop effective strategies for determining when and how any voting right held by the structure’s portfolio it manages is to be exercised, to the exclusive benefit of the vehicle and its investors”.
The strategies above mentioned must determine measures and procedures in order to monitor the relevant corporate actions, ensure the exercise of voting rights in accordance with the investment objectives and policies, and prevent any conflict of interest that could arise from the exercise of these voting rights.
Also it is mentioned that a description of the strategies and the details of the actions taken on the basis of those strategies shall be made available to the investors upon request.
This Proxy Voting Policy is designed and implemented in a manner reasonably expected to ensure that voting rights are exercised in the best interests of the vehicles and its investors.
Enviromental, Social and Corporate Governance
In respect of the European Regulation on Environmental, Social, and Governance (ESG) matters and particularly in connection with 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), Quamvest has implemented the following approach.
Enviromental, Social and Corporate Governance related disclosures
Disclosure on sustainability risk. Art. 3 of SFDR
At Quamvest, we understand that as a financial market participant we have to
manage not only financial matters and effects but also the potential
environmental, social and governance impacts of our investments. We believe that
by integrating ESG analysis into our investment process, we can create long-term
value, identify growth opportunities, and reduce the risk of ESG related harms,
while fostering sustainable investments. For this reason, starting in March 2021
and following the SFDR regulation, Quamvest has put in place an ESG Policy that
is recommended as a default option for each managed portfolio.
Given the variety of investment portfolios that Quamvest manages in cooperation
with different General Partners and Investment Advisors, the final adoption of such
policy is decided for each respective portfolio and requires the commitment of the
relevant actors. The adoption or not of such policy is thus disclosed in the relevant
documentation available to investors.
Disclosure on principal adverse impact. Art 4 of SFDR
In addition, the SFDR Regulation requires an AIFM to disclose its approach with
respect to the principal adverse impacts of its investments. Taking into
consideration the variety of investment portfolios that Quamvest manages in
cooperation with different General Partners and Investment Advisors, the final
adoption of ESG characteristic or a sustainability objective is decided for each
respective portfolio and requires the commitment of the relevant actors. When a
portfolio commits to either ESG characteristics or a sustainability objective, an
ESG procedure will detail the specific objectives, indicators and the related
evaluation of principal adverse impacts of its investment. For further information
on the portfolios/funds that promote ESG characteristics or a sustainability
objective, please refer to paragraph “Funds promoting ESG characteristics or
sustainable investment as its objective”.
Disclosure on Remuneration Policy
Quamvest does not promote in any case the assumption of excessive sustainability
risk either in the management of the Company or in the way its portfolios are
managed. Furthermore, variable remuneration is not linked to the specific
performance of any portfolio or fund and therefore there is not any explicit or
implicit incentive to assume undue sustainability risk. The overall attitude of each
professional towards risk management is a key qualitative variable remuneration
assessment criteria. For additional information, the remuneration policy is
published on Quamvest’s website under the “Regulatory Information” section
Funds promoting ESG characteristics or sustainable investment as its
Currently no funds promotes ESG characteristics or sustainable investment as