Gariel Nahoum
About Gariel Nahoum
Gariel Nahoum (year of birth 1983) serves as Chief Legal Officer since March 2025 solely for purposes of Sections 307 and 406 of the Sarbanes-Oxley Act; concurrently, he is General Counsel, U.S. Registered Funds, and Senior Vice President at Neuberger Berman Investment Advisers LLC (NBIA) . Officers who are employees of NBIA (like Nahoum) serve without any compensation from the Funds, and the proxy does not disclose individual officer compensation, ownership, or fund-level performance metrics such as TSR, revenue growth, or EBITDA trends .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| NBIA | General Counsel, U.S. Registered Funds | Since March 2025 | Designated Chief Legal Officer for 28 registered investment companies for SOX 307/406 purposes |
| NBIA | Senior Vice President | Since 2017 | Senior legal leadership supporting registered funds complex |
| NBIA | Associate General Counsel, Mutual Funds | 2017–2025 | Mutual fund legal counsel across NBIA funds |
| NBIA | Assistant General Counsel and Vice President | 2014–2016 | Legal and corporate responsibilities within NBIA |
External Roles
None disclosed for Nahoum in the NHS proxy .
Fixed Compensation
- Officers who are directors, officers, or employees of NBIA or its affiliates serve without any compensation from the Funds; the proxy does not provide Nahoum’s base salary or cash compensation (paid by NBIA, not the Funds) .
Performance Compensation
- The proxy contains no disclosure of officer bonus targets, actual bonuses, RSUs/PSUs, stock options, or performance metric weightings for Nahoum; the Funds do not maintain a standing compensation committee (Independent Director pay is handled by Governance and Nominating Committees) .
Equity Ownership & Alignment
- Officer-level beneficial ownership (shares, options, RSUs) and pledging/hedging disclosures are not provided; the “Ownership of Securities” table covers Directors and the Interested Director only (not fund officers) .
- Stock ownership guidelines and compliance status for officers are not disclosed in the proxy .
Employment Terms
| Item | Disclosure | Citation |
|---|---|---|
| Title/Scope | Chief Legal Officer since March 2025 (only for purposes of SOX 307/406); General Counsel, U.S. Registered Funds | |
| Officer status | Officers are elected by Directors, serve at the pleasure of the Board, and may be removed at any time with or without cause | |
| Compensation source | Officers employed by NBIA serve without any compensation from the Funds | |
| Severance/CoC terms | Not disclosed in the Fund proxy (NBIA-level employment terms not included) | |
| Clawbacks/Code of Ethics | CL0 designation aligns to SOX 307 (attorney conduct) and SOX 406 (code of ethics for senior financial officers) | |
| Non-compete/Non-solicit | Not disclosed | |
| Start date in role | March 2025 (CL0 designation); General Counsel appointment concurrent |
Investment Implications
- Transparency: Compensation, equity grants, and ownership for fund officers are not disclosed at the Fund level; officers are paid by NBIA, not the Funds, limiting visibility on pay-for-performance alignment and vesting-related selling pressure for NHS specifically .
- Governance/role clarity: Nahoum’s designation as Chief Legal Officer for SOX 307/406 signals responsibility for legal ethics and code-of-ethics oversight across the NBIA registered funds complex, but does not equate to economic alignment disclosures at the Fund level .
- Retention risk and trading signals: With no Fund-level employment agreement, severance, change-of-control details, or Form 4 data disclosed in the proxy, investors lack signals on retention incentives or insider selling pressure; officer service is at the pleasure of the Board, suggesting at-will removal without cause at the fund level, while NBIA governs actual employment terms .