Regulatory Disclosures

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.

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.

File name File type Date
2020 Shareholder Engagement Policy PDF September 21, 2020

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:

  • 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.

Top 5 execution venues

As investment firm, Dasym Managed Accounts is required to publish on an annual basis, for each class of financial instruments, the top five execution venues in terms of trading volumes where we have executed client orders in the preceding year and information on the quality of execution obtained. Such details are presented in the report, which can be downloaded below. This report covers the period from 1 January 2018 to 31 December 2019.

File name File type Date
2019 Top 5 execution venues PDF December 31, 2019