Remuneration Statement

 

Introduction:

The remuneration policy of InterVest Capital Partners Sarl purports to fulfil the requirements of (i) Article 12 and Annex II of the AIFM Law, (ii) the AIFM Level 2 Regulation, (iii) the AIFMD Remuneration Guidelines, (vi) CSSF Circular 18/698 and (vii) 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.

Purpose and Scope of the Remuneration Policy:

The primary goal of this policy is to structure remuneration in a manner that aligns with InterVest’s operational and financial strategies, as well as its risk tolerance levels. Designed in line with ESMA’s guidelines on sound remuneration practices, the policy encompasses all Identified Staff, which includes Board Members, Senior Management, and other significant functions that contribute materially to the AIFM’s risk profile.

Governance and Oversight:

  • Roles and Responsibilities: The policy is subject to annual review and approval by the Board, in collaboration with InterVest’s internal control functions (risk management, compliance, and internal audit). Each control function plays a specific role in ensuring that the remuneration structure does not encourage excessive risk-taking, thus aligning with investor interests and maintaining a robust governance framework.
  • Compliance and External Disclosure: The Compliance Officer prepares an annual disclosure report detailing the decision-making process, including insights from internal and external advisors. This disclosure outlines key elements such as pay-performance linkage, allocation of variable pay, and risk adjustment measures. This report is accessible to the CSSF and investors on request, providing transparency on the alignment of compensation with sound financial practices and regulatory standards.

Structure of Remuneration:

InterVest’s remuneration structure includes fixed and variable components, balanced to ensure financial independence while aligning individual and corporate performance. The framework is designed to promote ethical behavior, accountability, and a stable financial environment.

  • Fixed Remuneration: Fixed pay serves as the primary component of remuneration, based on industry benchmarks, role requirements, and individual experience. This portion is intended to be substantial enough to allow flexibility in the payment of variable remuneration, including the possibility of no variable remuneration in cases of poor performance.
  • Variable Remuneration: Variable remuneration, including the deferred option, is discretionary, with payments linked to individual, fund, and company performance. It includes cash bonuses and potentially other benefits, such as long-term incentive plans. The variable pay remains capped at a maximum of 200% of the fixed pay for senior management and 100% for other identified staff.

Integration of sustainability risks in the remuneration policy:

This disclosure is applicable to InterVest Capital Partners Sarl (referred to as “AIFM”), the alternative investment fund manager belonging to InterVest Capital Partners Group. The Sustainable Finance Disclosure Regulation (SFDR) defines sustainability risk as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment”.

In line with Art. 5 of the SFDR – Transparency of remuneration policies in relation to the integration of sustainability factors, the AIFM has assessed its own characteristics and developed remuneration policies and practices which appropriately align the risks faced (including Sustainability Risks of the AIFM and/or where relevant the Funds concerned) and provide adequate and effective incentives to its staff.

The remuneration policy has been approved by the Senior Management and Board of Managers and is applicable to all employees of the AIFM. The remuneration is divided into a fixed and a variable remuneration. In addition, the remuneration policy of the AIFM is consistent with and promotes sound and effective risk management (including sustainability risks), being in line with the business strategy, objectives, values and interest of the AIFM and does not encourage excessive risk-taking.

The remuneration policy integrates and promotes the prevention or mitigation of conflicts of interest. The policy is reviewed annually to ensure alignment with evolving sustainability objectives and industry standards.

Prevention of Conflicts of Interest:

InterVest Capital Partners has a clear conflicts of interest policy that ensures remuneration practices are free from bias. Identified staff are prohibited from using personal hedging strategies or insurance to undermine the risk alignment effects of their compensation arrangements. This reinforces the integrity of the remuneration policy and aligns it with investor interests.

Disclosure and Transparency:

Internal disclosure is provided to all employees to ensure they understand the performance and risk alignment criteria applicable to their roles. Externally, InterVest Capital Partners prepares an annual disclosure that details remuneration structure, decision-making processes, and performance metrics, ensuring transparency with the CSSF and stakeholders, as per regulatory requirements.

Monitoring and review of the policy:

The remuneration policy of InterVest Capital Partners is reviewed at least on an annual basis, and the outcome of the review is reported to the board of managers.

For further details on the remuneration policy, please contact the Conducting Officer – Compliance of InterVest Capital Partners at the following email address: b.hartmeier@intervest.com.

Last review date of this statement: September 2025