Legal statements

On this page, you will be able to find the following statements and/or documents:

1. Disclaimer
2. Privacy Statement
3. Regulatory Disclosures
4. Sustainability Statement
5. Shareholder Engagement Policy
6. Remuneration Policy
7. Top 5 execution venues

1. Disclaimer

This website contains general information regarding Dasym Holding B.V. and its worldwide affiliates and subsidiaries (collectively, hereinafter: “Dasym”).This information is a general description of Dasym only. Before acting on any information, you should consider the appropriateness of it having regard to your particular objectives, financial situation and needs and seek advice. No information set out on this website constitutes advice, an advertisement, an invitation, a confirmation, an offer or a solicitation, to buy or sell any security or other financial product or to engage in any investment activity, or an offer of any financial service. Some products and/or services mentioned on this website may not be suitable for you and may not be available in all jurisdictions. All securities and financial products or instrument transactions involve risks. Past performance of any product described on this site is not a reliable indication of future performance.

Dasym took the greatest possible care when compiling this website. However, it is possible that the information published is incomplete, incorrect or in breach of the law. In this context, Dasym will accept no liability whatsoever. Dasym has only made the information on the website available for informative purposes and under the explicit condition that you accept that Dasym cannot be held liable for the content of the information or any decisions made on the basis of the information published.

All the information on this website is the property of Dasym. The content may only be used for non-commercial/private purposes. Without the prior permission of Dasym, no part of the content of this website may be reproduced or made available to third parties.

2. Privacy statement

Rasile Group is committed to protecting your privacy. Under the General Data Protection Regulation (GDPR) you have certain rights with regard to your personal data. These rights are described in our privacy statement. This privacy statement describes how we (as a controller) use your personal data in our business operations. We collect, use, share and process personal data that are necessary for the purposes mentioned in this privacy statement or that are legally permitted.

If you have any questions about this Privacy Statement or our practices, please contact Compliance at +31 035 695 90 90 or

3. Regulatory disclosures

The name “Dasym” refers to Dasym Holding B.V. and its worldwide affiliates and subsidiaries. Dasym only carries on regulated activities in those countries it is authorized to do so.Dasym Managed Accounts B.V. is authorized by the Netherlands Authority for the Financial Markets and the Dutch Central Bank to carry out investment services in the Netherlands and a number of other EU jurisdictions, subject to regulation in the Netherlands and the regions in which it operates. Dasym Public Markets is a trade name of Dasym Managed Accounts B.V. Dasym Investment Strategies B.V. is registered as an exempt manager of alternative investment funds with the Netherlands Authority for the Financial Markets and the Dutch Central Bank. Dasym SICAV is an undertaking for collective investments in transferable securities (UCITS) with multiple sub-funds incorporated under Luxembourg law and authorized by the Luxembourg Commission de Surveillance du Secteur Financier pursuant to Article 129 of the law 17 December 2010 relating to undertakings for collective investment. The distribution of Dasym SICAV outside Luxembourg is subject to local legislation of the country of distribution. Dasym SICAV is distributed by Dasym Managed Accounts B.V. If you are considering a transaction in Dasym SICAV, then carefully consider the funds’ investment objectives, risk factors, charges and expenses before investing. This and other information can be found in the funds’ prospectus and the key investor information document, which may be obtained free of charge at the registered office of Dasym SICAV. Investors should read the prospectus and the key investor information document carefully before investing.

4. Sustainability statement

Dasym Managed Accounts B.V. (hereafter referred to as DMA) is a market participant and financial adviser as defined in European legislation. Currently, DMA does not consider the adverse impacts of its investment decisions or investment advice in a way that allows it to confirm consideration of sustainability factors. DMA continues to monitor and remain in dialogue with its clients on ESG issues and DMA may consider it appropriate to revisit this approach in the future.

DMA does not apply a general policy for integrating sustainability risks into its investment decisions or investment advice in respect of the products and services offered by DMA to its clients. DMA continues to monitor and remains in dialogue with its clients on ESG issues and DMA may consider it appropriate to integrate sustainability risks into its investment decisions and investment advice in the future.

5. Shareholder Engagement Policy

This Engagement Policy has been adopted by Dasym Managed Accounts B.V. to demonstrate compliance with the relevant regulatory requirements as prescribed under the Shareholder Rights Directive II, and relevant local transpositions across the European Union. The Shareholder Rights Directive II aims to promote shareholder engagement and improve stewardship practices across the European Union.

Please contact us if you would like to learn more about our Shareholder Engagement Policy.

6. Remuneration Policy

Dasym Managed Accounts B.V. (‘Dasym’) has a remuneration policy which abides by the national and international rules and regulations regarding sound remuneration principles. In implementing this policy Dasym has applied the proportionality principles which are commensurate with the size, complexity and nature of the organization[1].

This remuneration policy applies to persons who are employed by or otherwise in a relationship of authority to Dasym or related entities, including members of the Board of Directors and managers.

The remuneration policy is designed in such a way that:
The remuneration policy makes a distinction between certain categories of employees, such as ‘identified staff’[2] and enacts measures commensurate met the potential influence which these employees may have on the risk profile of Dasym.

The remuneration policy provides for measures for adjusting and reclaiming already awarded variable remuneration (malus and claw-back measures).

The governance of the remuneration policy provides for the following:
Given its size and non-complex structure, Dasym does not have a remuneration committee.

Key remuneration figures for 2019:
[1] Article 1:117, sub 2 Dutch Act on Financial Supervision (Wft).
[2] Identified staff means staff whose professional activities have a material impact on the institution’s risk profile in accordance with the criteria set out in the Commission Delegated Regulation (EU) 604/2014.

7. Top 5 execution venues

Dasym Managed Accounts is obligated to annually disclose, for each category of financial instruments, the top five execution venues based on trading volumes where we have executed client orders in the preceding year, along with information regarding the quality of execution obtained. This information is provided in the report, which can be downloaded below.