Investment Management Limited (“the Firm")
is authorised and regulated by the Financial Services Authority as a Limited
Licence Firm and so, it is subject to FSA Rules on remuneration. These are contained in the FSA's Remuneration
Code located in the SYSC Sourcebook of the FSA’s Handbook. The Remuneration
Code (“the RemCode”) covers an individual’s total remuneration, fixed and
variable. The Firm incentivises staff through a combination of the two.
business is to provide investment management services to the funds managed by
the Firm (the "Fund(s)")
is designed to ensure that we comply with the RemCode and our compensation
- are consistent
with and promotes sound and effective risk management;
- do not
encourage excessive risk taking;
measures to avoid conflicts of interest; and
- are in line
with the Firm's business strategy, objectives, values and long-term
in the European remuneration provisions is the principle of proportionality.
The FSA have sought to apply proportionality in the first instance by
categorising firms into 4 tiers. The Firm falls within the FSA's fourth
proportionality tier and as such this disclosure is made in line with the
requirements for a Tier 4 Firm.
Application of the requirements
is required to disclose certain information on at least an annual basis
regarding our Remuneration policy and practices for those staff whose
professional activities have a material impact on the risk profile of the firm.
Our disclosure is made in accordance with our size, internal organisation and
the nature, scope and complexity of our activities.
of information on the decision-making process used for determining the firm’s
remuneration policy including use of external benchmarking consultants where
The firm’s policy has been agreed by the
Senior Management in line with the RemCode principles laid down by the FSA.
Due to the size, nature and complexity of
the firm, we are not required to appoint an independent remuneration committee.
The Firm’s policy will be reviewed as part
of annual process and procedures, or following a significant change to the
business requiring an update to its internal capital adequacy assessment.
The firm’s ability to pay bonus is based on
the performance of firm overall and derived after the fund’s managed returns
have been calculated by client appointed third party administrators.
There is limited involvement of the firm in
deriving asset prices.
of how the firm links between pay and performance.
Individuals are rewarded based on their
contribution to the overall strategy of the business in relation to:
a. Investment Generation
b. Sales & Marketing
Other factors such as performance,
reliability, effectiveness of controls, business development and contribution
to the business are taken into account when assessing the performance of the
senior staff responsible for the infrastructure of the firm.
In accordance with CRD III and CEBS
guidance the Firm takes a proportionate approach to its Remuneration Code
disclosures in line with the nature, scale and complexity of the Firm and as
such has chosen not to disclose exact remuneration figures in regards to the
remuneration of the Code Staff identified by the Firm’s Policy. The Firm
confirms that all discretionary remuneration is directly related to the
performance of our managed entities and as such staff interests are innately
aligned with the interest of the Firm and its Clients vis-à-vis remuneration
information regarding the Firm’s financial data is made publically available
via the Firm’s audited accounts.
omit required disclosures where we believe that the information could be
regarded as prejudicial to the UK or other national transposition of Directive
95/46/EC of the European Parliament and of the Council of 24 October 1995 on
the protection of individuals with regard to the processing of personal data
and on the free movement of such data.