Governance and decision-making procedures:
The Firm is required to implement and maintain remuneration policies, procedures and practices for all directors and employees that are consistent with and promote sound effective risk management.
The policy is intended to cover all aspects of remuneration and has been created in accordance with the MIFIDPRU Remuneration Code (SYSC 19G).
The remuneration practices and policies are intended to:
- promote sound risk management practices in alignment with the Firm’s risk management principles;
- discourage risk taking that is inconsistent with the Firm’s risk appetite or risk management policies and principles;
- control fixed costs by ensuring that remuneration expense varies according to profitability and does not place undue constraints on the Firm’s ability to maintain its capital base;
- link remuneration to the Firm’s financial and operational performance as well as individual performance;
- provide competitive, but not excessive, levels of remuneration compared to peer Firms of appropriate size, scope, and complexity; and
- promote a positive culture towards risk management and compliance.
- The remuneration practices and policies are intended to support the Firm’s business strategy, long term interests and values, and to ensure that risk taking does not exceed the Firm’s tolerated level of risk.
Periodic benchmarking ensures that remuneration at individual level is not unreasonable or disproportionate to the amount, nature, quality, and scope of the work performed.
The remuneration policy outlines the criteria used to assess the performance of the Firm and of individual staff members. The Firm’s performance is assessed against its overall financial performance, as well as other measures such as new business gained, client satisfaction and employee retention rates.
In assessing the performance of individual staff members, the Firm takes into account financial and non-financial criteria. Non-financial criteria includes:
(a) measures relating to building and maintaining positive customer relationships and outcomes, such as positive customer feedback;
(b) performance in line with firm strategy or values, for example by displaying leadership, teamwork or creativity;
(c) adherence to the firm’s risk management and compliance policies;
(d) achieving targets relating to:
(i) environmental, social and governance factors; and
(ii) diversity and inclusion.