Since the introduction of the Alternative Investment Fund Managers Directive (AIFMD) in July 2013, alternative investment managers have been subject to a more stringent regulatory regime, designed to enhance investor protection.
If your fund operates under AIFMD, you need an independent depositary to oversee your fund’s activities. At Vistra, we're a leading service provider in terms of assets under administration (AUA) – so you know your fund is in safe, experienced hands. And with a dedicated team of senior lawyers and accounting officers, we ensure your fund is fully compliant with its depositary duties under AIFMD.
Our depositary services operate in three jurisdictions: the Netherlands, Luxembourg and the UK. As depositary, we monitor your assets according to local laws and integrate the depositary function with the rest of your global fund administration.
All our offices in the UK, Luxembourg and the Netherlands have depositary licences.
We've developed a unique operating model to give you an insight of how we operate as a fund depositary under the AIFMD. In five activities we take care of all steps necessary to be AIFMD compliant: onboarding, monitoring cash flows, ownership verification and record keeping and oversight duties.
An appropriate, transparent, and controlled remuneration policy is an essential part of the controlled conduct of business operations and the management of risks of Vistra Depositary Services B.V. (“VDS”). The remuneration policy VDS as described below is applicable to all the employees of VDS.
VDS remunerates its employees by way of fixed and variable monetary components paid in exchange for their labour.
Fixed remuneration consists of financial and non-financial criteria that are awarded unconditionally to the employee. In the case of a fixed remuneration, the reward for the preceding activities is established beforehand and is independent of the result of the actual labour performed by the employee. This fixed remuneration is laid down in a contract, guaranteed and independent of performance.
Variable remuneration is that part of the total remuneration that is not fixed. Variable rewards are dependent on the achievement of goals related to the said labour. As a result, the total amount of remuneration an employee will receive cannot be predicted in advance, but may depend on the performance provided by the employees. On average and on an annual basis, the variable remuneration shall never exceed 20% of the total fixed remuneration of all employees and per employee separately shall it never exceeds 100% of the fixed remuneration. There are no employees who received a total annual remuneration of €1 million or more.
VDS periodically evaluates whether adjustments to the remuneration policy are desirable or necessary.