On this page, you will be able to find the following statements and/or documents:
1. Disclaimer
2. Privacy statement
3. Regulatory disclosures
4. Sustainable Finance Disclosure Statement
5. Shareholder engagement policy
6. Remuneration policy
7. Top 5 execution venues
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.
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
compliance@dasym.com.
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. Sustainable Finance Disclosure Statement
The EU Sustainable Finance Disclosure Regulation (SFDR) aims to make the sustainability impact of financial market participants and products more comparable and better understandable for involved parties. Therefore, Dasym is obliged to have a Sustainable Finance Disclosure on its website. The SFDR is one of the many initiatives, which fall under the European Green Deal and EU Sustainable Finance Action Plan.
Dasym is a regulated boutique investment firm, offering tailor-made investment services. This focus on a tailored approach allows Dasym to service clients’ wishes in sustainability investments, preferences on ESG or Sustainable Development Goals or any feasible mix in asset portfolio. Dasym does not explicitly position itself as a sustainable asset manager, nor has Dasym included the consideration of adverse sustainability impacts in its investment policy.
Most of our current clients have a similar approach towards sustainability. As our clients have a long-term goal on capital preservation, their first priority is performance within the given risk appetite. Therefore Dasym implements ESG integration in the following way in its investment decision-making process: Dasym incorporates, if possible due to the type of investments, material environmental, social, and governance data and insights into investment making decisions, alongside traditional financial information, with the objective of improving the long-term financial outcomes of funds, portfolios and mandates.
Dasym may recommend sustainable investment products when these do not have outsized impact on risk adjusted returns. When potential clients have a full sustainability investment philosophy, Dasym welcomes them to engage with us, as Dasym can tailor their needs and ambitions with our independent, tailor-made asset management approach.
Dasym is the advisor for the VanEck Vectors Smart Home ETF. This product promotes environmental and social characteristics in alignment with Article 8 of the EU SFDR. As described in the prospectus, the Smart Home Fund ETF promotes environmental or social characteristics, but does not have as its objective sustainable investment. There are environmental and social characteristics that apply to the Fund’s investments.
- Firstly, the Fund promotes the reduction of the most negative impacts on society and the environment through reducing exposure to very severe controversies relating to international standards on responsible business, human rights and labour rights.
- Secondly, minimizing exposure to controversial business activities relating to tobacco, controversial weapons, energy extractives, civilian firearms and military.
- Thirdly, limiting exposure to carbon risk, by excluding companies deriving significant (>30%) revenues from energy extractives, such as thermal coal.
- The Glass Lewis ESG policy guidelines are applied whereby votes are cast on sustainability matters. The Engagement policy applies to the Fund, whereby active engagement with investee companies is an integral component of the investment process.
For our investment professionals who are involved with investments that promote environmental and social characteristics, specific targets aimed at responsible investing are incorporated.
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.
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:
- It ties in with the Dasym’s culture and strategy, objectives, values and long-term interests of the company and its stakeholders.
- It is ethical, sound and sustainable, in line with the Dasym’s risk appetite, risk management strategy and risk profile, contributes to robust and effective risk management, and does not encourage the taking of more risks than is acceptable to the business.
- It takes account of the interests of clients and is designed to ensure that clients are treated in such a manner that their interests are not harmed in the short, medium and long term.
- Performance by employees and by the Dasym itself are measured based on both financial and non-financial indicators.
- Remuneration practices do not contain any incentives that might prompt individuals to put their own interests before that of Dasym or its clients.
- It does not pose a threat to the solid capital base of Dasym.
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:
- Approval of remuneration policy, yearly remuneration, and the identification of identified staff is the responsibility of the management of Dasym.
- Oversight and review of the remuneration policy by the Compliance Officer who is independent of the business line.
- A yearly risk analysis of the remuneration policy by Compliance which is subsequently reported to management.
- Assistance by Human Resources in the identification of identified staff and annual reporting to Compliance concerning the working and effectiveness of the remuneration policy.
Given its size and non-complex structure, Dasym does not have a remuneration committee.
Key remuneration figures for 2019:
- The number of employees with a total annual remuneration (fixed and variable) of € 1 million or more for 2019 was 0 (2018: 0).
- The number of employees that received a variable compensation regarding their performance in 2019 was 0 (2018: 0).
- The total number of identified staff in 2019 was 7 (2018: 7).
- The number of identified staff that received variable compensation regarding their performance in 2019 was 0 (2018:0).
[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.
