Remuneration Disclosure – MIFIDPRU 8.6
Introduction
Anchor Capital Asset Management (UK) Limited (“ACAM”) is subject to the FCA Rules on remuneration as they apply to a small and non-interconnected (SNI) MIFIDPRU investment firm. These are contained in the FCA’s MIFIDPRU Remuneration Code located in SYSC19G of the FCA’s Handbook.
Approach to Remuneration for all staff
Employees have the opportunity to share in the success of the Company in years of good performance and also accept reduced levels of variable (bonus) pay in times of poor performance or losses.
ACAM does not remunerate or assess the performance of its staff in a way that conflicts with its duty to act in the best interests of its clients.
ACAM does not make any arrangement by way of remuneration, sales targets or otherwise that could provide an incentive to its staff to recommend a particular financial instrument to a client when the firm could offer an alternative financial instrument which would better suit the client’s needs.
ACAM is mindful of ensuring that its remuneration policy and practices do not lead to a conflict of interest or incentivise its staff to act in a manner that favours their own interests or the firm’s interests to the potential detriment of any client or potential client.
Objectives of financial incentives
ACAM’s Remuneration Policy provides a framework to ensure all staff are fairly and competitively rewarded in return for a high level of service to the firm and is clients. In setting remuneration levels ACAM recognises the importance of attracting and retaining experienced staff. The amount of fixed remuneration paid to an employee will be based on market rates relevant to the employee’s role and their knowledge, experience, and competencies. Discretionary bonuses are made to employees to reward them for good performance with a view to increasing and maintaining their productivity.
Decision Making
Senior management shall be responsible for the implementation of this policy as well as the monitoring of compliance risks associated with it. This policy will be reviewed and approved by the management body at least annually to ensure it continues to remain fit for purpose with the input from the firm’s Compliance Officer.
Characteristics of Remuneration Policy and Practices
Remuneration typically comprises of fixed and variable elements. Fixed remuneration consists of base salary, pension contribution and other benefits such as defined contribution pension, private medical insurance, life assurance which constitutes the fixed payment made to an employee for their services.
ACAM has defined variable pay as annual discretionary bonus, which is awarded based on company performance and individual performance. ACAM’s policy on variable remuneration is to set aside a proportion of the firm’s profits to form a bonus pool out of which awards will be
made. The total bonus pool amount is determined by reference to the Company’s risk-adjusted criteria, which include both quantitative and qualitative measures.
The firm will ensure that remuneration and similar incentives will not be solely or primarily based on quantitative commercial criteria. Consequently, the firm will take into account appropriate qualitative criteria (i.e. behavioural measures such as customer feedback) which shall encompass adherence with relevant regulations, fair treatment of clients and the quality of services provided to clients.
ACAM ensures it always maintains a balance between fixed and variable components of remuneration, so as to mitigate any conflicts of interest between the firm, its staff and its clients.
Remuneration for year ending 31-12-2024
| Staff remuneration (GBP) | |
| Fixed remuneration | £55,811.15 |
| Variable Remuneration | £0 |
| Total Remuneration | £55,811.15 |
