This page contains regulatory information specific to CVC Europe Fund Management S.à r.l ("CVCEFM"), a Luxembourg entity licensed by the Commission de Surveillance du Secteur Financier ("CSSF") as an authorised alternative investment fund manager in the meaning of the Luxembourg law of 12 July 2013 on alternative investment fund managers.
Complaints Handling Policy
A summary of the Complaints Handling Policy for CVCEFM is available below:
CVCEFM Complaints Handling Policy (PDF)
Proxy Voting policy
CVCEFM fully delegates the portfolio management function to entities within the CVC Network (each a "Delegate" and collectively the "Delegates"). CVCEFM deems that the Delegates are, in general, in the best position to exercise voting authority attached to relevant securities held by investment funds managed by a Delegate (each such fund, a "Fund", and collectively the "Funds") and have access to appropriate information to do so. For this reason, CVCEFM's operating model is to mandate the exercise of such voting authority to the Delegates.
CVCEFM shall select the Delegates based upon such delegates applying the following guiding principles to their approach:
- the Delegates shall implement monitoring of corporate actions;
- voting rights shall be exercised in accordance with the investment objectives and policies of the relevant Funds; and
- the Delegates shall seek to prevent and manage any conflicts of interest that may arise from the exercise of voting rights held by the Funds.
In the event any conflict of interest arises, CVCEFM and the Delegates shall seek to address such conflict of interest in the most appropriate manner and in accordance with any applicable Conflict of Interest Policy as and when such conflicts come to their attention.
Information on remuneration policy
The remuneration policy of CVCEFM is consistent with and promotes sound and effective risk management, including long-term sustainability risks, and does not encourage risk-taking which is inconsistent with the risk profiles, management regulations or instruments of incorporation of the funds. Compensation may include a variety of components and may vary from year-to-year based on a number of factors. The principal components of compensation include fixed base compensation and variable discretionary compensation.
CVCEFM ensures that the measurement of performance used to calculate the amount of variable remuneration is determined by taking into account the full range of current and potential risks associated with activities undertaken, including sustainability risks. The total amount of remuneration shall be based on a combination of the assessment of the performance of the individual and of the business unit or Fund concerned and of the overall results of CVEFM. When assessing the individual performance, the evaluation or appraisal of the relevant staff member shall be based on financial and non-financial criteria (e.g., unethical or non-compliant behaviour).
Best execution policy
CVCEFM is out of scope with regards to the Markets in Financial Instruments Directive (MiFID), as typical private equity transactions do not involve the trade of MiFID defined "financial instruments". Whenever best execution is relevant, CVCEFM has processes in place to ensure that it takes all reasonable steps to obtain the best possible result for the funds it manages or the investors in these funds.
Shareholders Rights Directive II Disclosure
Article 3(g) of Directive 2007/36/EC as amended by Directive (EU) 2017/828 (together with the relevant national implementing measures, the "SRD II") requires asset managers to adopt, on a "comply or explain" basis, an engagement policy describing how an asset manager integrates in its investment strategy shareholder engagement relating to companies which have their registered office in the EU and the shares of which are admitted to trading on an EU regulated market.
The investment strategy of the CVCEFM Funds (nor that of its Delegates) does not predominantly target investments in equity securities of EU listed issuers. In particular, CVCEFM Funds pursue private equity strategies, which are rooted in investing in non-listed companies. As a result, CVCEFM has chosen at this stage not to adopt an engagement policy pursuant to SRD II.
As part of the investment process, CVCEFM (or its Delegates) will exercise voting rights in investee companies as well as manage related conflicts of interest in accordance with existing policies. CVCEFM retains its own conflict of interests policy, as do its Delegates. Underlying investors in CVCEFM Funds can also consult the relevant private placement memorandum to assess how voting rights may be exercised and conflicts of interest will be managed. In view of its investment strategies and portfolios, CVCEFM considers that this approach remains in line with the objectives of SRD II. CVCEFM will periodically assess whether it becomes relevant for it to adopt an engagement policy and will update this disclosure accordingly.