MIFIDPRU 8 Disclosure

The Firm is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm is a UK domiciled discretionary investment manager to professional clients.

The Firm is categorised as a “SNI MIFIDPRU investment firm” by the FCA for capital purposes. The Firm reports on a solo basis. The Firm’s MIFIDPRU 8 disclosure fulfils the Firm’s obligation to disclose to market participants’ key information on a firm’s remuneration policies and practices.

In making the qualitative elements of this disclosure, the Firm is required to provide a level of detail that is appropriate to the Firm’s size and internal organisation, and to the nature, scope and complexity of its activities.

This disclosure is made annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure is made more frequently, for example if there is a major change to the Firm’s business model.


The Firm is subject to the Remuneration Code (the “Code”) for MIFIDPRU Firms as codified in Section 19G of the SYSC sourcebook of the Financial Conduct Authority handbook.

This disclosure sets out qualitative and quantitative information on the Firm’s remuneration processes and practices.

A. Qualitative Information

The Firm must establish, implement and maintain remuneration policies, procedures and practices that are consistent with and promote effective risk management and do not encourage excessive risk taking.

The Firm ensures that the remuneration policy and its practical application are consistent with the Firm’s business strategy, objectives and long-term interests.

Given the nature and size of the Firm, remuneration for all employees is set by the Firm’s management body.

Staff receive a salary which reflects their market value, responsibilities and experience.

Staff may also receive variable remuneration, such as an annual bonus, where the individual operates within the risk appetite of the company and has demonstrated appropriate behaviour.

Variable remuneration is intended to reflect the individual’s contribution to the Firm’s overall success. Staff are assessed throughout the year based on performance. The performance assessment considers both financial measures and non-financial measures.

The Firm’s linkage between variable remuneration and performance is based upon the following tenets:

  • Ensuring an appropriate balance of financial results between staff and shareholders
  • Attraction, retention and motivation of Staff
  • Aligning the interest of senior staff via long-term incentive awards
  • Linking a proportion of an individual’s total compensation to the Firm’s performance
  • Discouraging excessive risk-taking and ensuring that client interests are prioritised

B. Quantitative Information

Given the nature and size of our business, remuneration for all employees is set by the Firm’s management body. The Firm formally reviews the performance of all employees and based thereon determines each employee’s overall level of remuneration and the split of that between base salary, bonus, etc. in compliance with the FCA Rules on remuneration.

Quantitative disclosures in relation to remuneration may be omitted where it is believed that the information could be regarded as prejudicial to our adherence to the data protection regulation on the protection on natural persons regarding the processing of personal data and on the free movement of such data.

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