INTRODUCTION

The Firm is a MiFIDPRU investment firm and the following disclosures have been made in accordance with the FCA’s MiFIDPRU remuneration requirements. This Remuneration Disclosure (the “Disclosure”) has been produced to satisfy the requirements of the MIFIDPRU 8 Disclosure requirements and provides a summary of the Firm’s qualitative and quantitative disclosures.

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REMUNERATION PHILOSOPHY

Our remuneration philosophy and the objectives of our remuneration practices are consistent with and promote sound  and effective risk management aligned with the business strategy, objectives and long-term interests of the Firm. The Firm’s remuneration arrangements are designed to:

• promote risk awareness and encourage responsible business conduct;

• reinforce positive cultures and the values of the Firm;

• encourage responsible business conduct;

• align the interests of staff with the long-term interests of the clients and the Firm

• commensurate with the Firm’s risk appetite;

• avoid conflicts of interests; and

• offer reasonable and competitive remuneration to attract and retain high calibre employees.

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GOVERNANCE AND REPORTING

All remuneration decisions are approved by the Board of Partners who are responsible for overseeing and implementing the Firm’s remuneration practices. The Firm does not have a Remuneration Committee on the basis that it would be disproportionate for the size and scale of the Firm.

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COMPONENTS OF REMUNERATION

The Firm categorises all remuneration as either fixed or variable remuneration based on the ‘quality’ and ‘purpose’ of the remuneration. All employees are remunerated with an annual fixed salary and variable payments determined at the discretion of the Firm. The Firm pays fixed and variable remuneration in a balanced way with the fixed component representing a sufficiently high proportion of the total remuneration that enables the Firm’s policy to work flexibly and includes the possibility of the Firm paying no variable remuneration. Fixed remuneration is remuneration that primarily reflects a staff member’s professional experience and organisational responsibility as defined in their job description and terms of employment; and is permanent, pre determined, non-discretionary, non-revocable and not dependent on performance. Variable remuneration is remuneration that is based on performance or, in exceptional cases, other conditions that reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment.

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FINANCIAL AND NON-FINANCIAL ASSSESSMENT CRITERIA 

The Firm considers both financial and non-financial criteria when assessing individuals for the purposes of determining the amount of variable remuneration to pay. Non-financial criteria form a significant part of the performance assessment process, override financial criteria, where appropriate, include metrics on conduct, which make up a substantial portion of the non-financial criteria and include how far the individual adheres to effective risk management and complies with relevant regulatory requirements.

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TOTAL REMUNERATION AWARDED TO ALL STAFF

For the period the total amount of remuneration awarded to all staff comprised:

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SUMMARY OF SIGNIFICANT CHANGES

There have been no significant changes to the Firm’s Remuneration disclosure compared to the previous period other than to adopt the disclosure requirements required under MIFIDPRU.

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TIMING OF DISCLOSURE

This disclosure is published annually.