Remuneration Policies

The Barings Group includes two Management Companies located in the European Union (each a ‘Firm’ and together the ‘Firms’):

  1. Baring Fund Managers Limited (“BFM”). Authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom
  2. Baring International Fund Managers (Ireland) Limited (“BIFMI”). Authorised and regulated by the Central Bank of Ireland (“CBI”)

The Firms are subject to the following European Directives:

  1. Undertakings for Collective Investment in Transferrable Securities (“UCITS”) Directive. [Directive 2014/91/EU, amending Directive 2009/65/EC]
  2. Alternative Investment Fund Managers Directive (“AIFMD”). [Directive 2011/61/EU]

Each Firm acts as manager to a number of UCITS funds and Alternative Investment Funds (“AIFs”) (together the ‘Funds’).

In accordance with the above directives, Management Companies are required to have a documented remuneration policy.  Key details of the remuneration policies for the above Firms are noted below.  Paper copies of these remuneration policies are available on request.

1. Remuneration Policy Framework

The purpose of each Firm’s remuneration policy is to seek to ensure that the remuneration arrangements of “identified staff”:

  1. are consistent with and promote sound and effective risk management; and do not encourage risk-taking which is inconsistent with the risk profile, rules or instruments of incorporation of the Firm or any fund which the Firm is the manager of; and
  2. are consistent with the Firm’s business strategy, objectives, values and interests and include measures to avoid conflicts of interest.


2. Applicable Remuneration

The principles set out in each Firm’s policy apply to fixed and variable remuneration of any type paid by each Firm including carried interest (if applicable), discretionary pension benefits and to any transfer of units or shares of the firm or any Fund.

3. Identified Staff

Each Firm is responsible for determining the categories of staff whose professional activities have a material impact on the risk profile of the Firm or any of the Funds they manage. Each Firm is also responsible for complying with the requirements which aim to manage the risks their activities entail ('Identified Staff').

The term “Identified Staff” broadly includes:

  • Senior management
  • Risk takers
  • Control functions
  • Employees in the same remuneration bracket, whose professional activities have a material impact on the Firm’s risk profile or of the Funds it manages

Neither Firm has any employees and investment management is delegated to Baring Asset Management Limited (“BAML”).  Persons falling into the category of Identified Staff for each Firm are:

  1. Directors of the Firm employed by BAML;
  2. Directors of the Firm independent of BAML;
  3. Risk and portfolio management staff at BAML whose professional activities have a material impact on the risk profile of the Firm and the Funds; and
  4. Risk and portfolio management staff seconded to the Firm whose professional activities have a material impact on the risk profile of the Firm and the Funds.

The UCITS and AIFMD Directives allow that when delegating an activity to a firm that is subject to remuneration rules that are equally as effective, the UCITS and AIFMD remuneration rules need not apply. 

BAML is subject to the Capital Requirements Directive (“CRD”) including its remuneration rules which are considered to be equally as effective as those under the UCITS and AIFMD Directives.  Employees of BAML are therefore subject to the CRD remuneration rules.

4. Directors

Directors of the Firm employed by the appointed Investment Manager have waived their right to a director’s fee.

Each director independent of the Investment Manager receives a fixed fee appropriate to their responsibilities and in line with the market rate.  Performance based or variable remuneration is not paid.

5. Risk and Portfolio Management Staff

Risk and portfolio management staff employed by BAML are subject to the CRD remuneration rules (as an equivalent body of rules).

Risk and portfolio management staff seconded to the Firm of BAML are subject to the UCITS and AIFMD remuneration principles (see below).  


6. Remuneration Principles

Identified staff for each Firm that are not employed by BAML are subject to remuneration principles as defined by the UCITS and AIFMD Directives.  These remuneration principles can be viewed here.

7. Remuneration Committee

On the basis of an assessment of the nature, scale and complexity of each Firm’s business structure and activities, each Firm’s Board has considered it is appropriate to dis-apply the requirement to appoint a remuneration committee.

8. Oversight of Remuneration Policy

The remuneration policy is adopted by each Firm’s Board and is subject to an annual review by the Firm. This review ensures that:

  • the overall remuneration system operates as intended;
  • the risk profile, long term objectives and goals of the Firm are adequately reflected; and
  • the policy reflects best practice guidelines and regulatory requirements.