Luxembourg Fund Governance Survey 2022


PwC Luxembourg, together with the Institut Luxembourgeois des Administrateurs (ILA), is pleased to introduce the latest edition of this Luxembourg Fund Governance Survey. In this 11th edition of the survey, insights were gathered from the boards of 137 investment funds and management companies covering both liquid and alternative products, breaking the record of 122 participants set in the previous edition. This increasing number demonstrates the continued attention market participants are paying to good governance.

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19/01/2023 |
  • Pwc

Given Luxembourg’s position as Europe’s largest fund centre and as the world’s leading cross-border investment fund centre, it is imperative that good governance practices become the norm across the boards of all market participants. Since its inception, the survey has been a valuable means through which stakeholders have obtained insights into current good governance practices and strengthened the overall governance framework in Luxembourg’s fund industry. The survey complements numerous other tools – such as publications, codes of conduct, events, courses, and workshops – developed and provided by ILA and the Association of the Luxembourg Fund Industry (ALFI), several of which are referenced in the survey.

This year’s survey reveals that boards are becoming increasingly attuned to AML- and ESG- related developments and legislations, both current and upcoming. Regulatory developments, coupled with ESG and investment performance, are the areas boards believe will require the most attention in the upcoming two years.

Michael Delano, ILA Fund Committee Chairman and PwC Luxembourg Partner, and Andrea Montresori, incoming ILA Fund Committee Chairman and PwC Luxembourg Partner said:

“At a time of increasing macroeconomic instability and geopolitical uncertainty across Europe, Luxembourg’s fund industry – and the financial centre as a whole – has remained resilient and has proven to be more than capable of weathering turbulent storms. Good governance practices have become heavily internalised across the industry, and this is one of the core reasons.

This year’s survey builds on the new additions made to the previous edition, particularly regarding ESG. With the increasing number of ESG-related regulations coming into force in Europe, and with the growing attention stakeholders in the global asset and wealth management industry are showing towards ESG, the latest edition of the survey examines how participants in the Luxembourg fund industry are reacting. Unsurprisingly, ESG is increasingly occupying a prominent position in boards’ agendas. In addition, given the Financial Action Task Force’s visit to Luxembourg in 2022, the survey dedicates a whole new section to AML. Promisingly, the overwhelming majority of boards have put in place strong policies and frameworks to combat AML and the financing of terrorism. We expect these two topics, alongside regulatory developments and changes, to continue to figure prominently as issues of concern for participants in the fund industry in future editions of the survey.

We would like to sincerely thank all 137 directors and chairpersons who took the time to share their thoughts and insights by participating in the survey, the members of the ILA Fund Committee for designing the survey, and our colleagues from PwC Luxembourg’s Global AWM & ESG Market Research Centre for analysing the data and preparing the report.”

As with the previous edition, the survey is divided into key areas of interest: board composition looks at the profiles of board members (age, gender, tenure, expertise, independence); board organisation examines practical details regarding board activities (such as the duration and frequency of board meetings); roles and responsibilities of the board highlights the different management styles of boards and the take-up of the ILA Certified Director program, among others; conflicts of interest & legal liabilities looks at how boards manage and mitigate potential conflicts of interest; code of conduct reviews’ boards adoption of and views on the ALFI Code of Conduct.

What’s new this year?

However, the 2022 edition includes two new sections: The first deals with AML and examines a wide array of AML-related matters, such as the extent to which boards have approved and validated AML policies; the second deals with ESG, which looks at boards’ ESG-related policies, communications, opportunities, and risks.

The survey ends with a section on the current challenges & looking forward, which explores the strategic and operational implications of the latest and upcoming regulations, as well as the issues and challenges boards expect to be facing in the coming two years.

Carine Feipel, Independent Director and Attorney at Law – Chair of the ILA said:

“Every two years, the ILA-PwC Fund Governance Survey is awaited by market participants to find valuable information about market trends and governance best practices. This 11th edition again evidences a number of improvements in the governance of investment funds and management companies.  It also shows the focus of boards on ensuring compliance with regulatory requirements, notably on ESG and AML. The training of board members remains a key priority in order to enable them to fulfil their roles. We are grateful for the input of the many participants in this survey, as well as all the persons who have worked on the analysis of the data received and the production of this survey.”

ILA & PwC Annual Fund Day 2023

On Tuesday 17 January 2023, ILA and PwC Luxembourg had the pleasure of once again hosting the Annual Fund Day at PwC’s premises in Crystal Park. Over 200 stakeholders from across the Luxembourg fund industry attended the event and listened to discussions and presentations on a wide array of fund-related topics and issues.

Michael Delano and Carine Feipel kicked off the morning session, welcoming attendees and providing an overview of the ILA’s plans and activities scheduled for 2023. They were followed by an update on the FDX Data Standard Initiative by independent director Mark Philips. PwC partner and EMEA Asset & Wealth Management Leader, Steven Libby, and independent director Jon Griffin provided the keynote address, sharing valuable insights on how to transition from ‘executive’ to ‘non-executive’ director, while PwC Luxembourg partner and Financial Services Market Leader, Olivier Carré, explained the fiduciary duties and governance associated with Articles 8 and 9 of the Sustainable Finance Disclosure Regulation (SFDR), highlighting the risks of greenwashing. Philippe Ringard (CEO of JP Morgan Asset Management Luxembourg) and Mike Delano, shared lessons learned on the new self-assessment and separate report, while Alain Hoescheid and Pascal Berchem (Chefs de Service at the CSSF) were interviewed by Sophie Dupin (Partner at Elvinger Hoss Prussen), highlighting some of the challenges associated with new regulations.

The afternoon session was kicked off by Michele Eisenhuth (Partner at Arendt) and Emmanuel Gutton (Director of Legal and Tax at ALFI) who discussed some of the current hot topics in the Luxembourg fund industry – such as the current and upcoming regulatory changes, alongside the FATF Evaluation Report and AML, to name a few.

Andrea Montresori then presented the results of the Fund Governance Survey and discussed the findings with Martin Vogel (Global Head of Strategy at Waytone) and independent directors Valérie Warland and Tracey McDermott. The ‘digital lifecycle’ was the next subject of discussion, with a discussion between independent director Martin Dobbins, Olivier Portenseigne (CEO of FundsDLT), Jack Ehlers (COO and Managing Director Europe of Bitstamp) and Philippe Van Hecke (Head of Product Management at the Luxembourg Stock Exchange). Independent director Revel Wood and Justin Griffiths, Partner at Deloitte, introduced the new guidelines in the ALFI Code of Conduct, while independent directors Anne Canel and Vanessa Klein (Risk manager at EQT) discussed the SFDR through the perspective of private equity. An update on AML was provided by Birgit Goldak (Partner at PwC) and Guilhem Ros (CSSF). Michael Delano concluded the event by interviewing Marco Zwick (Chef de Service at the CSSF).

ILA and PwC are proud to have hosted yet another successful Annual Fund Day, packed with challenging questions from the audience and insightful discussions on the crucial topics impacting the Luxembourg fund industry. We look forward to collaborating next year.

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