1. Remuneration system

A central element of the remuneration policy is the consistent alignment of the remuneration system with the Company’s strategic corporate objectives in conjunction with the performance of the individual employees. Any variable compensation rewards sustainable performance and avoids incentives to take inappropriate risks.

1.1 Compensation principles

The remuneration of the employees is freely negotiated and contractually agreed.

Each employee of the Company receives an appropriate, fixed annual salary, which is paid in twelve equal monthly installments. In addition to the annual salary, employees can also be granted other fixed remuneration components such as a lunch allowance or a local transport ticket. The criteria for any necessary adjustment of fixed salaries and for the specific amount of the discretionary bonus are, among other things, the performance of the individual employee and the respective division and the historical development of the individual employee’s remuneration.

The total salary may include a variable component. Voluntary retirement benefits may also be a component of compensation for the Company. In individual cases, one-off and voluntary special payments are made for special individual benefits or extraordinary burdens.

The total pool of variable compensation as the sum of the determined maximum achievable amounts of variable compensation is reviewed before being granted as to whether this total volume is appropriate with regard to the Company’s economic situation and liquidity; otherwise the variable compensation is reduced if necessary.

1.2 Identified Employees

The company’s structures are transparent, characterized by a flat hierarchy and not comparable to a listed company. There is no systemic relevance for the financial market. In addition, transactions are only carried out in accordance with the business permit.  Against the background of many years of experience in the management of real estate funds, the standardised processes that have been tried and tested over many years also contribute to a well-functioning and reliable process organisation.

Against this background, the Company has identified the following (employee) group within the meaning of § 37 KAGB:

Members of the Management Board (in accordance with VI. No. 20 of the ESMA Directive)

Other risk carriers, employees with control functions or other employees with a total remuneration corresponding to that of a managing director or risk carrier were not identified.

The risk carriers are generally identified on the basis of their hierarchical position, their remuneration, the extent of their competencies within the Company and a review of their potential functional impact on the overall risk profile of the Company and the funds managed by the Company. The details of the decision-making process for determining these employee groups are separately documented and regularly reviewed.

1.3 Compensation system for „identified employees

1.3.1 Variable remuneration

The amount of the portion of the variable remuneration – which is to serve exclusively as an additional individual performance incentive – is determined in an appropriate proportion to the portion of the fixed remuneration. This implies that the ratio must be determined separately for each identified employee (group). In this respect, certain employees – for example in control functions – may also be granted fixed remuneration exclusively or at least almost exclusively.

The variable remuneration is granted exclusively on a performance-related basis. The amount is determined on the basis of the employee’s achievement of objectives within a defined period (usually a fiscal year).

1.3.2 Risk and performance measurement

With regard to the performance of variable remuneration components, the Company relies more strongly on flexibility and individuality in accordance with its corporate culture and taking into account the size of the company, insofar as this is permissible under supervisory law from an employment law perspective for all employees and in particular for identified employees falling within the scope of the KAGB. The variable remuneration of an employee is always measured on the basis of individual performance.

The following different target levels can be included in the power rating:

Individual goals and
Corporate goals.

The variable remuneration is thus based on the company’s success, but also takes into account the individual contributions of each employee.

The variable remuneration is generally limited to a maximum of 50% of the annual fixed salary.

Where individual targets are agreed, this is done on the basis of the employee’s activities and, in particular, the associated risks. With regard to the tasks and responsibilities of the respective employee, an appropriate mix and thus a balance between quantitative and qualitative targets as well as the employee’s position and responsibility must be observed when setting targets.

1.3.4 Payment method of variable compensation

The variable remuneration is paid in full in cash to the employee at the end of the fiscal year. The payment of part of the variable remuneration in the form of instruments and the application of a vesting period shall be waived in accordance with the principle of proportionality set out in ESMA’s „Guidelines for sound remuneration policies taking into account AIFMD“.

Due to the investment strategies pursued by the AIF (real estate investment assets), there is little potential to take on special atypical risks. These investment strategies are essentially characterised by long-term real estate investments and imply the expectation of stable and steady cash flows and returns, both at the level of the investment fund and at the level of the company.

1.3.5 Severance payments

As a rule, the Company does not provide employees with severance pay when they leave the Company in order to avoid incentives for failure.

1.4 Compensation System for „Unidentified Employees

The proportion of the variable remuneration of the remaining employees is determined in an appropriate proportion to the proportion of the fixed remuneration. In principle, the variable portion of the remuneration for employees who are not considered identified employees within the meaning of Section 37 KAGB shall not exceed 50% of the annual fixed salary. There is no time deferral of shares in the variable remuneration or their (partial) payment in instruments. The actual amount of the variable remuneration may be linked to the fulfilment of performance targets or target agreements.

Governance and Compensation Committee

2.1 Shareholders and Supervisory Board

The remuneration policy is designed and adopted by the shareholders of the company. The Supervisory Board is informed of significant changes to the remuneration policy.

The implementation of the company’s remuneration policy is reviewed at least once a year by the shareholders to determine whether the remuneration system as a whole is suitable as intended, i.e. in particular appropriate and compatible with national and international regulations, principles and standards. The agreed remuneration and the basic system are reviewed on an annual basis in the first quarter of each calendar year. The aim of the review is to compare the salary structure of comparable employee positions, to question remuneration in line with market conditions and thus to analyse the optimum effect of the remuneration system on employee satisfaction and thus on employee loyalty.

The members of the Company’s Supervisory Board do not receive incentive-based compensation.

2.2 Compensation Committee

The Company has not yet established a Compensation Committee. In accordance with regulatory requirements, the Company is not an AIFM of significant importance, in particular because the variety of investment strategies managed is very limited (essentially real estate investment assets) and therefore the possibilities for taking special atypical risks are extremely limited.