BIPRU firm Remuneration Policy
The Remuneration Policy is designed to support key business strategies and create a strong, performance-orientated environment. At the same time, the policy must attract, motivate and retain talent.
It is important that the policy follows the SYSC rules (namely SYSC Chapter 19C – Remuneration Code) and addresses the importance of ensuring that all variable remuneration is subject to risk- based profit performance and is not seen to reward misconduct or poor performance at the individual, unit or firm level.
Executive directors (and other senior/management/control function staff, namely those falling within the definition of Remuneration Code Staff – taken to include senior management, risk takers, those performing a significant influence function or who are paid like senior management or risk takers) receive base salaries proportionate with companies of their size with the added opportunity to enhance total remuneration by receiving bonuses based upon the overall performance of the company and takes this into account when determining remuneration policy and practice for other employees.
The components of remuneration for code staff comprises of a base salary, which takes the form of a fixed sum payable monthly which is reviewed annually and other benefits including non-contributory health insurance, a potential quarterly annual bonus and pension contributions.
A successful remuneration policy must ensure that a significant part of the remuneration package is linked to the achievement of stretching corporate performance targets. The policy adopted by the company ensures that a proportion of the remuneration of executives and others is aligned with corporate performance. As a result, depending on the performance of the company, some staff may receive a bonus exceeding 33.3% of their base salary.
The Committee has agreed that the Company falls within Proportionality Level 3 in accordance with the revised remuneration code and has identified those employees that fall within the scope of that code.
In the FCA’s view, it will be normally appropriate for a BIPRU firm to disapply, under the BIPRU remuneration proportionality principles, the following rules:
- retained shares or other instruments (SYSC 19C.3.47R);
- deferral (SYSC 19C.3.49R);
- performance adjustment (SYSC 19C.3.51R); and
- the ratios between fixed and variable components of total remuneration (SYSC19C.3.44R).
Policy on Salary of Executive Directors
It is the company policy to pay base salaries to the executive directors broadly at market rates compared with those of executives of companies of a similar size, whilst also taking into account the executives’ personal performance and the performance of the Group. All directors and senior managers are required to sign a conflict of interest disclosure.
Policy on Bonus
The bonus in the case of all employees including executive directors is designed to reward outstanding performance and to be consistent with the company’s approach to risk. The company bonus pool will be based on risk-adjusted profits. All bonuses will reflect the performance of the individual, the business unit and the firm. No bonus will be guaranteed.
The Firm has determined that sustainability risk (which is defined as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the relevant investment (an “ESG Event”)) is not relevant for the funds that the firm manages.
The funds are based on major financial indices and derivatives structured around major financial indices and, as such, an ESG event would not be relevant to the funds.
Policy on Long-Term Incentives, Executive Share Options, Performance Share Plans Pensions
Should any of these become applicable they will be added as an annex to this document.
Policy on Service Contracts
In relation to contracts with executive directors, the company sets notice or contract periods at three months. If it is necessary to offer longer notice or contract periods to new directors recruited, it is the company’s policy to reduce these as soon as contractually possible after the initial period to a notice period of one year.
Executive directors are permitted, where appropriate and with Board approval, to take non-executive directorships with other organisations in order to broaden their knowledge and experience in other markets and countries.
Remuneration Code Staff
This comprises all employees whose professional activities have a material impact on the firm’s risk profile, including senior management and other staff exercising control functions, risk takers and any staff whose pay puts them in the same remuneration bracket as senior management and risk takers. Code Staff are informed of their classification.
The identified Remuneration Code Staff are as follows:
All senior management and all staff holding a certified function as defined under the SM&CR regime.
Remuneration Code Staff can be exempt from certain strands of the code requirements on the basis that the variable proportion of their remuneration comprises no more than 33% of their total remuneration and their total remuneration is no more than £500,000. Applications to the FCA need to be made for any exemptions as outlined above. For a Proportionality Level 3 firm, the firm should carefully consider the wisdom of application for exemption as many of the requirements can be disapplied.
Remuneration Code Staff exemption applications:
No exemption applications.