Remuneration Code Disclosure

The Firm's business is to provide investment management services. The Firm’s remuneration policy is designed to provide sufficient rewards and incentives to the Firm’s employees to encourage performance of the highest standard while supporting the Firm’s business strategy, and fostering long term value creation. The policy is also risk focused in order to promote sound and effective risk management.  Specifically the Firm's remuneration policy is designed to ensure that remuneration arrangements are; consistent with and promote sound and effective risk management, do not encourage excessive risk taking,  include measures to avoid conflicts of interest and are in line with the Firm's business strategy, objectives, values and long-term interests.
As a Tier 4 Firm the Firm’s remuneration policy is structured to be appropriate and proportionate in relation to the size of the Firm, the Firm’s internal organisation and the nature, scope and complexity of the Firm’s activities and
to be in compliance with FCA Remuneration Rules and other applicable law and regulations. In order to achieve these aims the Firm’s remuneration policy is designed to ensure that individual remuneration is aligned with the Firm’s long-term performance and the interests of all of the Firm’s stakeholders.
The Firm has identified those employees registered with the FCA and performing significant influence functions as meeting FCA criteria for Code Staff. The Code Staff population is reviewed at least annually and is updated
as required to reflect Code Staff leavers and joiners.
The Firm’s remuneration framework is based on a total reward approach and is designed to reflect success or failure against a range of targets. These targets are defined within a business balanced scorecard (which includes suitably risk adjusted factors) covering firm, group, financial, and personal performance. There are two components of remuneration:
1. Fixed – cash salary set within an appropriate market range.
2. Variable – cash bonus, payable solely at the discretion of the Firm and sufficiently flexible to allow the possibility, where performance so warrants, that an employee may receive no variable awards based on business and individual performance.

We have omitted the quantitative disclosures in relation to remuneration as we believe that, in view of the size of the Firm and the limited number of Code Staff, the information could be regarded as prejudicial to our adherence to the General Data Protection Regulations on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.