Remurenation Policy

3K INVESTMENT PARTNERS MUTUAL FUND MANAGEMENT COMPANY SINGLE MEMBER SA REMUNERATION POLICY

INTRODUCTION

The present remuneration policy of "3K INVESTMENT PARTNERS MFMC SINGLE MEMBER SA" (hereinafter "the Company") incorporates the provisions of articles 23a and 23b of Law 4099/2012, Article 13 of Law 4209/2013, as well as the Annex I no. 11 of the decision no. 8/459/27.12.2007 of the Board of Directors of the Capital Market Commission, as amended by decision no. 28/606/22.12.2011 of the Board of Directors of the Capital Market Commission and was specified by Circular 48 of the Capital Market Commission.

The Company, in implementing this Remuneration Policy, does not discriminate against its employees and executives on the basis of race, color, gender, religion, political opinion, national or social origin or other status.

1. PURPOSE OF ESTABLISHING A REMUNERATION POLICY

The aim of this policy is to promote the correct and effective management of risks, including sustainability risks*, to discourage the taking of excessive risks, as well as risks incompatible with the risk profile, the Regulations of the mutual funds managed by the Company, as well as not hindering the Company from acting in the interest of the mutual funds under management. Also, the objective of this policy is that the Company's remuneration structure does not encourage excessive risk-taking in relation to sustainability risks and is linked to risk-adjusted performance.

*"Sustainability risk" is defined as an environmental, social or governance event or circumstance that, if it occurs, could have an actual or potential material adverse effect on the value of an investment.

2. SCOPE

2.1. In accordance with the applicable legislative and regulatory framework, the remuneration policy should be applied to the categories of employees, which include senior management, risk-takers, persons exercising control functions and any employee receiving total remuneration that places them in the same pay scale as senior management and risk-takers whose professional activities have a material impact on the risk profile of the Company, the individual portfolios and mutual funds it manages.
According to the above, the remuneration policy applies to the following categories of executives/employees of the Company:

• to the members of the Board of Directors,
• to senior management,
• to the Compliance Officer,
• to the Risk Management Officer,
• to the Internal Auditor,
• to Fund Managers,
• to individual portfolio managers,
• to the Company's Executives,
• to any employee of the Company who receives total compensation that places him in the same pay scale as senior management and risk takers, whose professional activities have a material impact on the risk profile of the Company or the individual portfolios or mutual funds that it manages and
• to any employee of the Company, whose professional activities have a material impact on the risk profile of the Company or the individual portfolios or mutual funds it manages.

2.2. The principles reflected in this remuneration policy apply to any benefit of any kind paid by the Company, to any amount directly paid by the mutual funds themselves, including performance fees, as well as to any transfer of shares of the mutual funds for the benefit of the persons referred to in point 2.1. above.

2.3. Remuneration means payments and benefits of any kind received by the aforementioned persons, directly or indirectly through affiliated enterprises, in exchange for professional services provided by them through a dependent or non-dependent employment relationship, such as salaries, optional pension benefits, variable remuneration or benefits dependent on the employee's performance or contractual terms, guaranteed variable remuneration and payments linked to early termination of contract.

2.4. For the application of this policy, the terms "fixed" and "variable" remuneration have the following meaning:

• Remunerations that are not linked to staff performance are considered fixed.
• Variable remuneration is considered additional payments or benefits, which depend on the performance of the staff or on contractual conditions.

Supplementary payments or benefits, which are attributed without discrimination to the staff, are part of the general policy of the Company and do not provide incentives to take risks, are not included in the definition of variable remuneration.

3. BASIC PRINCIPLES-PRACTICES OF EMPLOYMENT

The remuneration policy is based on the following basic principles:

To enhance the effectiveness of employee motivation, clear, measurable both quantitative and qualitative goals are set at the beginning of each year. These goals include the Company's goals regarding sustainable development. In addition, long-term incentives ensure the achievement of long-term goals and create alignment between the interests of employees and the interests of the Company and shareholders.

The remuneration policy is in line with the business strategy, objectives, values and long-term interests of the Company, the funds under management and the shareholders of these funds, and includes measures to discourage conflicts of interest.

Personnel with audit duties are independent of the business units they supervise, have appropriate powers and are remunerated based on the achievement of objectives related to their duties, regardless of the performance of the business areas they audit.

In particular, the remuneration of senior executives in the risk management and regulatory compliance functions is directly supervised by the Company's Board of Directors.

Total remuneration is divided into fixed, variable and ancillary. Fixed remuneration represents a sufficiently high proportion of total remuneration, in order to allow for a fully flexible policy on variable remuneration, including the option not to be paid.

Where remuneration is linked to performance, the total amount of remuneration is based on a combination of an assessment of the performance of the individual or the relevant fund and its risks, as well as the overall results of the Company at the time the individual performance is assessed. When evaluating individual performance, the financial and qualitative (non-financial) criteria mentioned in point 4 of this policy are taken into account.

Performance-related pay is assessed on a three-year basis to ensure that the evaluation process is based on long-term performance and that the payment of performance-related components of pay is spread over a period of time that takes into account the underlying business cycle of the company and its business risks. Specifically for managed funds, the performance assessment is framed within a three-year framework adjusted to the holding period recommended to unitholders of managed funds to ensure that the assessment process is based on the funds' long-term performance and their investment risks and that the payment of performance-related remuneration is distributed over the same time period as above.

Variable remuneration is paid only when the Company makes a profit and thus strengthens its capital base and is subject to the achievement of the Company's goals in terms of sustainable development. Accordingly, the payment of variable remuneration does not weaken the Company's capital adequacy, does not encourage excessive risk-taking in relation to sustainability risks and is linked to risk-adjusted performance. Guaranteed variable remuneration is prohibited. Exceptionally, they are allowed only in the case of hiring new staff and are limited to the first year of employment. Early termination payments reflect performance over time and are designed so that failure is not rewarded.

The variable remuneration, including its suspended part, is paid or vested only if it is acceptable on the basis of the overall financial situation of the Company and justified on the basis of the performance of the Company, the relevant business unit of the relevant mutual fund and the relevant member of staff, as well as subject to the achievement of the Company's goals in terms of sustainable development.

Subject to the general principles of national labor law, including the provisions on employment contracts, the total variable remuneration will generally shrink significantly when the Company or the relevant mutual fund shows poor or negative financial performance. Downsizing involves both current earnings and reductions in past pay through malus or clawback arrangements or other arrangements.

The pension policy is in line with the business strategy, objectives, values and long-term interests of the Company and the funds under management. If the employee

The pension policy is in line with the business strategy, objectives, values and long-term interests of the Company and the funds under management. If the employee leaves the Company before retirement, the optional pension benefits are retained by the Company for a period of five years, in the form of the means referred to in paragraph 5.1. only for the part of them that exceeds 50,000 euros per year contribution by the Company to the pension in application of the principle of proportionality and in accordance with the conditions listed below under 5. In the case of an employee who retires, optional retirement benefits shall be paid in the form of the means referred to in paragraph 5.1. with the obligation of a five-year holding period, only in respect of their portion that exceeds 50,000 euros per year contributed by the Company to the pension fund in application of the principle of proportionality and in accordance with the conditions listed below under 5.

Staff must not use personal hedging strategies or fee- or liability-linked insurance to circumvent risk-alignment mechanisms included in remuneration arrangements.

Variable remuneration is not paid through mechanisms or methods that facilitate the avoidance of the requirements of this policy.
The Company must adjust its contractual obligations with the staff to ensure compliance with the provisions of this policy.

4. REMUNERATION STRUCTURE - VARIABLE REMUNERATION CALCULATION MECHANISM

4.1. Remuneration structure

The remunerations paid by the Company are divided into fixed, variable and ancillary and have the meaning given to them in point 2.4 of this policy. It is noted that the Fixed salaries are the guaranteed income received by the employee and are not linked to his performance.

Regarding Fixed salaries, the Company has created salary scales, which ensure a comparable return of fixed salaries to the holders of positions of similar importance.

Regarding the Variable remunerations, the following applies: a) they are linked to the achievement of the Company's objectives and are a key component of its policy, which is oriented towards performance, b) their payment is not binding for the Company. This means that the payment of variable remuneration may not take place if the Company is not profitable or if the conditions set in the applicable legislative and regulatory framework are not met.

Given that the fixed wages paid by the Company represent a fairly high part of the total wages of each employee/executive, it is obvious that the non-payment of variable wages does not create a problem for the worker/executive to maintain his standard of living.

4.2. Variable remuneration calculation mechanism.

The amount of variable remuneration paid by the Company is determined by the combination of the evaluation of the performance of the individual, the Department/Division in which he/she works (if applicable), the overall results of the Company and - if applicable - the performance of the Company's managed mutual funds and their risk profile.
Particularly:

a) The evaluation of individual performance is carried out on an annual basis and is based on the degree of achievement of the qualitative and quantitative goals set at the beginning of each year based on the services provided by the specific person to the Company. Quantitative targets are determined each time depending on the professional activity carried out and the degree of its impact on the risk profile of the Company or of the mutual funds under management. Quality objectives include:

• efficiency in the execution of duties,
• ability to organize and plan,
• spirit of cooperation,
• correct setting of goals and priorities,
• finding solutions,
• effective crisis management
• contribution to the achievement of the Company's goals in terms of sustainable development and
• timely completion of schedules.

b) The evaluation of the performance of the Department/Division to which the evaluated person belongs (if applicable), is determined based on the degree of achievement of the quantitative and qualitative objectives at the Department/Division level (from all the persons who belong in the specific Department/Directorate).

c) The evaluation of the Company's performance is carried out on an annual basis, taking into account its financial results, the degree of achievement of operational and sustainability goals, the business plan and the Company's capital adequacy and liquidity indicators.

The aforementioned qualitative and quantitative goals participate in finding the final percentage of achievement of the set goals by a specific percentage (%) of weight, which is determined by a relevant decision of the Company's Board of Directors. With the same decision, the Company's Board of Directors determines the minimum final percentage of goal achievement for the activation of the variable remuneration payment mechanism. Based on the final target achievement rate, the final amount to be paid is calculated as follows: (Operating Profit – Proportionate Tax – 10% of Equity capital) *20%).

5. PAYMENT OF VARIABLE BENEFITS AND SUSPENSION OF PAYMENT.

It is noted that based on the principle of proportionality, as it is applied based on the circular 48/11.05.2012 of the Capital Market Commission and the ESMA Guidelines for the correct remuneration policies based on the UCITS directive (with number 2016/575-EL), the mentioned below under 5.1., 5.2. and 5.3. are not applied when the total amount of (if any) variable remuneration to be paid per person per year does not exceed the amount of 50,000 euros.

Notes:
(a) The time of payment of the variable retirement benefits of the pensioner is defined as the time of redemption by the employee of his portion thereof and
(b) The time of payment of variable remuneration by the Company to the beneficiary is defined as the time the amount is credited to the employee's account.

The invocation of the principle of proportionality, as mentioned above, is done taking into account the following criteria:

• The total number of employees in the Company: 24 employees.
• The fact that the Company has no branches and has not established subsidiaries, as well as that it manages UCI’s with simple investment strategies that have not introduced their shares to an organized market and do not invest in derivative financial products.
• The fact that the Company provides services exclusively in Greece and Cyprus.
• Regarding the Company's risk exposure, the fact that the Company monitors the individual risks related to market risk, to which its portfolio is exposed, sets limitations and limits on its trading portfolio, while it does not have investment positions in derivatives and securitization instruments.
• The fact that the Company's capital adequacy ratio is at high levels and exceeds the requirements against the risks to which it is exposed
  In any case, the variable remuneration, including the part under suspension, is paid or vested only if it is acceptable on the basis of the overall financial situation of the Company and justified on the basis of the performance of the Company, of the business unit in question, of the UCITS/AIF if applicable, and the staff member in question, as well as on the condition of achieving the Company's goals in terms of sustainable development. Also, it is always ensured that the total amount of variable remuneration and the method of its payment does not limit the Company's ability to strengthen its capital base.

5.1. 50% of the variable remuneration will consist of shares of the funds under management or equivalent ownership rights, taking into account the regulation of the mutual funds. The instruments referred to in the previous sentence are subject to a holding corresponding to the holding period recommended to the shareholders of mutual funds or equivalent ownership rights in order to align the incentives with the long-term interests of the Company, the mutual funds under management and their shareholders. It is noted that in the event that the value of the portfolio of the mutual fund under management is less than 50% of the value of the entire portfolio managed by AEDAK, the minimum percentage of 50% does not apply.

5.2. The settings of paragraph 5.1. they apply both to the part of the variable remuneration, the payment of which is suspended according to the following paragraph 5.3., and to the part of the variable remuneration which is not suspended.

5.3. The payment of 40% of the variable remuneration is deferred for a period of 3 years, which is considered appropriate taking into account the holding period recommended to the shareholders of the respective fund and is properly aligned with the nature of the risks of the fund in question. The percentage of variable remuneration, the payment of which is deferred, in accordance with the aforementioned, is paid proportionally distributed over the aforementioned period of time.

6. IMPLEMENTATION MONITORING - REVIEW.

This remuneration policy has been approved by a relevant decision of the Company's Board of Directors. The Company's Board of Directors reviews the remuneration policy at least annually, taking into account the recommendations of the Company's Internal Auditor and oversees its implementation. The above tasks are carried out by the non-executive members of the Company's Board of Directors who have expertise in risk management and remuneration policies.

Reference date: 28.02.2022