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This website contains material produced and managed by, or on behalf of, Apheon Management S.A. (hereafter, “Apheon”), registered with the Luxembourg Trade and Companies Register under number B – 215461 and authorized as an Alternative Investment Fund Manager (“AIFM”) by the Luxembourg Supervisory Authority of the Financial Sector – Commission de Surveillance du Secteur Financier (“CSSF”) since 9 May 2018 under the number N°A00002088, with input from its affiliates, as appropriate.

The information provided on this website does not constitute individual, legal, investment or tax advice about any of the funds or investments presented therein. Moreover, it neither constitutes an offer to enter into an investment agreement with Apheon, nor an invitation for such an offer. It is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution would be contrary to local law or regulation.

Remuneration Policy

In accordance with applicable regulatory framework, including but being not limited to Article 5 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 29 November 2019 on sustainability-related disclosures in the financial services sector, as well as Article 14 of the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainabilityrelated disclosures in the financial services sector, and Article 14 of the European Securities and Markets Authority’s Guidelines on sound remuneration policies under the UCITS Directive and AIFMD, Apheon has implemented a remuneration policy under which Apheon pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonuses), which are not based on the performance of the AIFs under management. Variable remuneration is determined on the basis of financial and non-financial criteria including compliance with all of Apheon’s (i) policies and procedures and (ii) internal risk management framework and risk limits, including those related to the integration of sustainability risks, both in Apheon’s activities and also in the investment decision-making process.

Complaint Handling Procedure

Apheon is committed to addressing complaints promptly, fairly, and transparently, in accordance with regulatory requirements.

Apheon has established a comprehensive Complaint Handling Procedure (the “Procedure“) in accordance with the following regulations and circulars:

    • CSSF Regulation 16-07 related to out-of-court resolution of complaints.
    • CSSF Circular 17/671.
    • CSSF Circular 18/698.

For the purpose of this Procedure, a complaint is defined as any expression of dissatisfaction, regardless of its reasonableness, from or on behalf of any individual or entity (the “Complainant“) regarding the services provided, or the failure to provide a service, which the Company has agreed to offer. The Complainant seeks some form of redress or remedy. While complaints can be oral or written, Apheon kindly request all potential Complainant to submit a complaint in written, in order to be able to treat it.

Complaints can be submitted to Apheon’s Complaints Handling Officer through various channels, including:

    • In writing:

Apheon Management S.A.
Attn: Complaints Handling Officer
19-21 Route d’Arlon
L-8009 Strassen

By email, at the following address: compliance@apheon.com

Complainants are required to provide the following information to ensure prompt handling of their complaint:

    • Complainant’s identity and contact details.
    • The reason(s) for the complaint.
    • If applicable, include copies of any supporting documentation.

Upon receiving a written complaint, it will be acknowledged in writing within ten (10) business day of receipt of the complaint, unless the answer itself is provided to the Complainant within this timeframe.

If the complaint requires further investigation, a response will be sent to the Complainant within one month of receipt. If the AIFM cannot provide an answer within this timeframe, the Complainant will be informed of the reasons for the delay and provided with an expected response date.

Should the response be unsatisfactory, the Complainant has the option to escalate complaint to the CSSF for an out-of-court resolution. Such filing must occur within one year from the date of filing the complaint with Apheon. Detailed procedures for out-of-court complaint resolution with the CSSF can be found on the CSSF website: https://www.cssf.lu/en/customer-complaints/

Voting Rights Policy

Apheon prioritizes professional corporate governance standards and view the exercise of voting rights at general meetings as a crucial element of our ongoing dialogue with the companies we invest in on behalf of our managed funds and their investors. Apheon’s Voting Rights Policy is committed to consistently and responsibly exercising voting rights to preserve the best interests of its investors. Voting decisions are aligned with the investment objectives and policies of the Funds managed by Apheon, and steps are taken to prevent and manage any conflicts of interest.

Apheon’s voting strategy focuses on promoting effective corporate governance, the fair treatment of shareholders, transparency in financial reporting, and the competence and independence of board members. Apheon exercises voting rights with the aim of maximizing the long-term value of the managed Funds as well as their investors. The policy is reviewed annually to ensure compliance with national and international regulations and standards.

Whistleblowing Policy

At Apheon, integrity is a fundamental value, and this is reflected in its Whistleblowing Policy, which outlines the rules and procedures for whistleblowing. The policy applies to all individuals associated with Apheon, including employees, suppliers, freelancers, subcontractors, investors, and business service providers. Its purpose is to create an atmosphere of transparency and accountability, ultimately upholding Apheon’s legitimacy. Whistleblowers are encouraged to report misconduct and violations in good faith, with false reports leading to legal and internal consequences. The policy protects those reporting any wrongdoing that could impact Apheon’s interests, covering a wide range of violations such as regulations, laws, ethics, client protection, and more. Apheon has established a confidential internal whistleblowing channel through the email address, which is accessible only to designated Referents (designated as Apheon’s CFO and Compliance Officer), ensuring privacy:


The Referents are responsible for conducting investigations and reporting their findings within a specific timeframe, with a focus on protection and resolution. Importantly, retaliation against whistleblowers is strictly prohibited, and Apheon is committed to safeguarding individuals who report misconduct in good faith, regardless of the accuracy of the reported facts. However, the misuse of the mechanism for allegedly false reports is subject to legal and internal disciplinary consequences.