Mountains

Remuneration Policy

Purpose

This policy sets out the Remuneration Policy of Margetts Fund Management Ltd (the ‘firm’) in relation to Code Staff and Managers performing Compliance and Risk functions.  It takes account of the rules and requirements set out in Senior Management Arrangements, Systems and Controls (SYSC) of the Financial Conduct Authority (FCA) source books.

The Remuneration Policy is designed to allow the risks associated with remuneration to be better managed and to avoid undue risks associated with it.  This Remuneration Policy has been designed to support the strategy and long-term interests of the firm, its shareholders and customers.

The Remuneration Policy should be read in conjunction with the completed FCA Remuneration Code Template for BIPRU companies.

Responsibilities

The Remuneration Committee consists of all the nominated independent non-executive Directors.

The Remuneration Policy is reviewed and adopted by the Remuneration Committee. It will be reviewed at least annually and:

  • On a significant change to the business activities of the firm;
  • On a significant change to a business relationship which forms a material part of the business of the firm; or
  • At such other point as the Board or Remuneration Committee considers necessary in order to comply with the principles contained in this Policy.

Following recommendations made by the Chief Executive, the Remuneration Committee has responsibility for decisions relating to remuneration for all Code Staff and reviews remuneration of Officers and Managers performing Compliance and Risk functions.  This includes fixed and variable elements of remuneration and discretionary pension benefits.

The implementation of the Remuneration Policy is subject to a central and independent review by compliance to ensure any potential conflicts are identified and managed.

The Board will be responsible for ensuring this process is followed and the external auditors are required to report to the Board and the Remuneration Committee on an annual basis as to adherence to the Remuneration Policy.

Application

The Remuneration Committee recommendations reflect the Board’s policy to reward performance based on profitable, sustainable and compliant behaviours.

Individuals’ remuneration consists of a basic package which is payable in any event and represents a market rate for the duties undertaken.  Additional payments are discretionary and will only be awarded on the basis that the individual has contributed to the long-term sustainable well-being of the business and the firm’s business strategy measured across a range of factors including profitability, training and competence, compliance with the FCA’s requirements and other factors considered relevant. The Remuneration Committee will take into account the long-term interests of investors, other stakeholders and the public interest.  When assessing individual performance both financial and non-financial criteria are taken into account and this will include the performance of the individual, the business unit or fund concerned and also the overall results of the firm.

The Board’s approach to variable remuneration is such that all variable remuneration is discretionary in nature and will not jeopardise the firm’s current regulatory capital position, future identified capital planning needs nor its ability to respond to any identified risk that it will need to strengthen its capital base.

Any variable remuneration can be reclaimed in the event of gross misconduct or gross or wilful negligence.  This can include adversely affecting the reputation of the firm such as bringing the firm into disrepute or a breach of contract of employment or engagement.  Examples of this could be inappropriate behaviour, suppressing documents, inflating trading income and discrimination in the workplace.

The following sources of revenue are used to determine variable remuneration:

  • Fees from assets under management;
  • Fees from advisory services;
  • Fees from ACD services;
  • Fees from the provision of investment research.

When considering the above, consideration is also give to the following risks, capital and liquidity factors:

  • Consistency, timing and likelihood of revenues;
  • Decline in value of funds under management or advice through market movements, investment performance or departure of clients;
  • Decline in value of fees from ACD services as a result of structural change;
  • Departure of staff and potential impact on future revenues;
  • Pressure on fees and competitor pressure;
  • The cost and quantity of capital and liquidity requirements;
  • The impact of future increases in the cost of administering the business arising from both inflationary and decision (i.e. future expansion) factors.

The firm’s pension policy is standard and there are no individual discretionary awards.  This does not form part of performance-related remuneration and no discretionary pension benefits are paid to retirees.

Variable remuneration will not exceed twice the fixed remuneration and will only exceed once the fixed remuneration if it has been agreed by the Board by resolution and approved by shareholders representing at least 50.1% of the issued share capital.

The firm will not guarantee any variable remuneration and will ensure any payments in relation to early termination reflect performance and not reward failure.  Apart from Variable Bonuses, payment of which has been authorised by the Remuneration Committee, the Remuneration Policy expressly prohibits any other payment (whether made directly or indirectly) to be made to any Remuneration Code Staff other than those relating to fixed salaries, proper reimbursement of expenses and dividends paid on ordinary shares.