Our Policies
U Fund Services S.à r.l. (“UFS” or the “Company”) is a fully authorized Alternative Investment Fund Manager (“AIFM”) under the Law of 12 July 2013, supervised by the Commission de Surveillance du Secteur Financier (“CSSF”). In accordance with applicable European and Luxembourg regulations, UFS has implemented a robust governance framework supported by comprehensive internal policies to ensure regulatory compliance, investor protection, and operational integrity.
Voting Rights Policy
This policy is established in accordance with the Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU of the European Parliament and of the Council on Alternative Investment Fund Managers (the “AIFMD”) and Luxembourg applicable regulations. UFS exercises voting rights attached to instruments held in the portfolios of the AIFs it manages exclusively in the interest of investors and in line with each fund’s investment strategy. Voting rights are exercised for the benefit of AIFs and their investors. All voting decisions comply with the fund’s prospectus, constitutional documents, and governance framework. The records of voting events, decisions taken, and any related conflicts are maintained to ensure transparency and accountability.
Conflict of Interest Policy
In accordance with Article 14 of the AIFMD and CSSF Circular 18/698, UFS has implemented procedures to identify, prevent, manage, and disclose conflicts of interest. The policy applies to all staff, delegates, and relevant people. A register of conflicts is maintained and reviewed by the Compliance Officer and the Board. Escalation and disclosure procedures ensure transparency when organizational measures are insufficient.
Complaints Handling Policy
This policy complies with CSSF Regulation 16-07 and Circulars 17/671 and 18/698. UFS ensures that complaints are handled fairly, promptly, and transparently. A Conducting Officer acts as Complaints Officer and liaises with the CSSF. Complaints are logged, investigated, and resolved, with annual reporting and trend analysis performed to improve service delivery.
Remuneration Policy
In line with Article 13 of the AIFMD, ESMA Guidelines (ESMA/2013/201), and SFDR Article 5, UFS’s remuneration policy promotes sound risk management and discourages excessive risk-taking. The policy includes fixed and variable components and is reviewed annually by senior management and the Board.
Data Protection Policy
This policy is aligned with Regulation (EU) 2016/679 (GDPR) and Luxembourg Data Protection Law. UFS ensures lawful, fair, and transparent processing of personal data. Measures include privacy by design, breach reporting, data subject rights, and oversight by a Data Protection Officer. Transfers outside the EU are subject to adequacy decisions or appropriate safeguards. Any data breach is reported to the CNPD and affected data subjects without delay.
Note: UFS reviews its policies annually and updates them in accordance with changes in regulation, operational structure, or investor needs.
Billel is responsible for developing internal policies and procedures, conducting risk assessments and compliance audits, and ensuring strict adherence to regulatory requirements. He also oversees compliance reporting to maintain a robust regulatory framework.
Before joining UFS, Billel worked at an AIFM in Luxembourg, gaining extensive expertise in fund governance, regulatory compliance, AML/CFT, and operational oversight.
Billel holds a Master’s degree in Finance from IMC Business School and initially pursued studies at the IT engineering school EFREI in Paris. He further expanded his academic experience with a semester abroad at Asia Pacific University in Kuala Lumpur and has completed several certifications in Compliance and RC Capacity. A native French speaker, Billel is also fluent in English.
Marco is Senior Fund Administrator and responsible for the onboarding and review of new and existing investors, as well as monitoring transactions between investors and funds (Capital Call, Distribution, Transfer of Shares, Capital Account Statement).
Before joining UFS, Marco gained valuable experience working with top tier Fund Administrators as a Transfer Agent.
Before transitioning to the financial sector, Marco spent 10 years in the logistics and international transportation industry.
Marco has an academic background in Social Sciences and Communication, as well as in Linguistic Mediation, which he pursued in Italy. Additionally, he has completed several trainings in Luxembourg on AML/CFT and Compliance. As a native Italian speaker, Marco is fluent in English and Spanish. He also possesses intermediate knowledge of French and a basic understanding of German.
Oussama is a Senior Fund Administrator, specializing in AML/KYC compliance, transfer agency, and portfolio analysis. In his role, he oversees investor onboarding, ensures regulatory compliance, and supports operational efficiency.
Before joining UFS, Oussama gained valuable experience working with global banks and Alternative Investment Fund Managers.
Oussama holds a Bachelor’s degree in International Business, completed partly in China, and a Master’s degree in Finance & Investment from the United Kingdom. Fluent in English, French, and Arabic.
Hafid is responsible for Compliance and AML/CFT and brings extensive experience in regulatory compliance, AML/CFT, and fund administration in Luxembourg. He is a Certified Anti-Money Laundering Specialist (CAMS) and holder of the RC Capacity.
Before joining UFS, Hafid held leadership roles at top-tier organizations, including Big Four firms and several banks. He has served as a Board Director for regulated and non-regulated funds and AIFMs, overseeing governance and compliance in alignment with Luxembourg and European regulations.
Hafid is adept at managing large teams, optimizing compliance processes, and implementing robust risk management frameworks. With a strong track record in governance, compliance, and AML/CFT strategy, he is dedicated to upholding the highest standards of regulatory excellence and operational integrity.
Hafid holds a Master’s degree in Finance from the IUP of Nancy, France. He is a native French speaker and fluent in English.
Nicoletta is responsible for implementing investment portfolio and marketing policies and procedures, while ensuring compliance with statutory and regulatory requirements. She oversees and approves investment decisions across all funds, ensuring alignment with portfolio strategy and regulatory requirements.
Before joining UFS, Nicoletta worked as Portfolio & Marketing Manager at one of the leading global AIFMs and fund service providers, where she oversaw portfolio investment approvals and ongoing monitoring of closed-ended AIFs, analyzing and approving hundreds of investment transactions. Prior to that, she worked at the European Parliament in the Accounting and Treasuring Unity being responsible for the application of the Financial Regulation and monitoring the transaction within the SAP interface.
Nicoletta holds a Master´s degree in Finance Management Engineer and a Bachelor’s degree in Management Engineer both from Politecnico of Milan. She also completed several internships in Milan and Finland as Management Engineer working on the implementation of Finance Market Place and SAP Platform for SME. Nicoletta is a native Italian speaker, fluent English and has intermediate knowledge of French.
Stephan is Conducting Officer for Valuation & UCI, as well as a member of the Board of Directors at UFS. He is responsible for UCI Administration, Valuation and ensuring compliance with statutory and regulatory requirements in line with CSSF standards.
With over 26 years of experience in the Luxembourg finance sector, Stephan’s expertise spans Risk Management, Compliance/AML, Valuation, and UCI Administration. He has led multiple CSSF-authorised AIFM Management Companies and managed complex portfolios across asset classes including Private Equity, Real Estate, Private Debt, Infrastructure, Insurance-linked assets, and Fund of Funds. Before joining UFS, Stephan served as Conducting Officer in several AIFMs and held senior leadership roles. He has successfully led multiple initial applications for AIFM licences and asset class sub-licences.
Stephan holds a Master’s and Bachelor’s degree in Business Administration from the University of Göttingen and the University of Marburg. He is a CFA Charterholder and a Certified Financial Risk Manager (FRM). A native German speaker, he is fluent in English.
Youssef is Risk & Operations Manager and is responsible for the implementation of risk compliance policies and procedures, carrying out the statutory/regulatory duties, as well as acting as the RC for all Ufenau Funds.
Before joining UFS, Youssef worked as Risk & Valuation Manager at IQEQ responsible for the ongoing risk monitoring of a portfolio of closed-ended AIFs focused on all asset classes: Private Equity, Real Estate, Private Debt, Fund of Funds, and Infrastructure.
Prior to that, he worked at IQEQ Group supporting the Group Management Board and the Group Executive Committee in their roles and various duties to further expand the organic and inorganic growth of the Company.
Youssef holds a Master’s degree in Business Administration and a Bachelor’s degree in Marketing. He also completed several internships in Canada and Luxembourg as a Marketing and Communication Officer. Youssef is a native French speaker, fluent in English and has intermediate knowledge of Spanish.
Youssef is responsible for designing and implementing the risk management framework, overseeing operational processes, ensuring regulatory compliance, and supporting governance across all managed funds. He also contributes to defining the strategic direction of the company and driving its long-term growth and positioning in the market.
Before joining UFS, Youssef worked as Risk & Valuation Manager at one of the leading global AIFMs and fund service providers, where he was responsible for the ongoing risk monitoring of a portfolio of closed-ended AIFs covering multiple asset classes: Private Equity, Real Estate, Private Debt, Fund of Funds, and Infrastructure. Prior to that, he supported the Group Management Board and the Group Executive Committee in their strategic initiatives and governance duties to drive both organic and inorganic growth of the company.
Youssef holds a Master’s degree in Business Administration and a Bachelor’s degree in Marketing. Youssef is a native French speaker, fluent in English and has intermediate knowledge of Spanish.
