Conflicts of interest
Please refer to the downloadable document below for information on potential conflicts of interest and how to deal with them.
Principles for dealing with conflicts of interest
Disclosure report according to the Institutsvergütungsverordnung and in conjunction with Article 450 of the EU-Capital Requirements Regulation 575/2013
(Last updated 15/03/2018 )
7orca Asset Management AG is not a prominent institution within the meaning of the Institutsvergütungsverordnung (InstVergVO), meaning that the presentation and scope of information relating to our remuneration policy conform to article 450 of the EU CRR no. 575/2013 without having to fulfil the additional provisions of paragraph 16 I and II of the InstVergVO. Although the company does not qualify as a CRR investment firm and hence not as an institute within the meaning of EU CRR no. 575/2013, the analogous application of article 450 comes into effect in accordance with paragraph 1a II of the German Banking Act (Kreditwesengesetz – KWG).
7orca Asset Management AG specialises in financial portfolio management for institutional clients and generally provides its services to capital management companies for the account of investment funds. In so doing, we predominantly pursue systematically and quantitatively oriented investment strategies.
The company´s remuneration principles meet the requirements of the German Banking Act (KWG) and those of MaComp (Mindestanforderungen Compliance) – minimum requirements for compliance – which were communicated to each employee at the end of his/her employment contract. Presently, the company employs another nine workers in addition to the three members of the executive board. All members of the executive board as well as the persons involved in portfolio management are relevant persons according to the (MaComp).
The executive board is responsible for the appropriate design and implementation of the remuneration system as well as the avoidance of remuneration-related risks, in as far as the remuneration of the the other employees is concerned. In contrast the supervisory board of the company is responsible for the remuneration principles of the executive board in a corresponding manner.
The remuneration principles are reviewed at least once a year with the participation of the compliance officer, and they currently contain a fixed and a variable component.Bonus regulations for all employees starting from a low threshold value are subject to the approval by the supervisory board.
The remuneration structure and implementation plan must be aligned with our business and risk policy, and hence be of benefit to the sustainable development of the company. Consequently, the payment of a variable remuneration is always subject to the company havingadequate capital and liquidity.
A variable remuneration scheme did not take effect in 2017 due to the fact that the company was at an early stage of development. Even beyond 2017, the essential remuneration component for all employees is fixed and no significant dependencies on bonus payments arise. In general the variable remuneration depends on the overall success of the company as a whole and does not lead to disproportionate risks. This is also accommodated by the fact that the strategies we pursue are strongly rule-based and are not dependent on individual portfolio managers for their implementation.
The fixed remuneration of employees is paid in twelve monthly payments per year and is calculated in such a manner that no incentives for disproportionately risky transactions are created. The variable remuneration is paid annually, where payment is applicable, and is capped in accordance with the provisions of the German Banking Act (KWG).
Execution Venues
The files that can be downloaded below contain information in German on the identity of the most important trading venues and on the quality of execution.
Meldung Ausführungsplätze 2017.pdf
Informationen zu Handelsplätzen.pdf
Ausführungsplätze 2018.pdf
Informationen zu Handelsplätzen 2018.pdf
Complaint Management
We aim to meet the requirements and standards of our customers and investors with our services and products at any time. If there is nevertheless cause for complaint, you can contact us free of charge electronically, in writing or verbally.
We have established effective and transparent complaint management procedures. This includes confirming receipt of a complaint without delay and providing you with information on how the complaint is handled. All complaints are immediately brought to the attention of the board.