Quilter Investors Limited (“the Firm”) has in place a Remuneration Policy (“the Policy”) in accordance with the rules of its regulator, the Financial Conduct Authority (“FCA”).
The Firm’s Board is responsible for approving and maintaining the Policy, which is designed to align the Firm’s remuneration practices with its risk tolerance and is also ultimately responsible for awarding remuneration and benefits in the Firm. The Board has delegated oversight of the Policy and its application to the Quilter Remuneration Committee. The Quilter Remuneration Committee is composed of independent non-executive directors of the Firm.
The Firm is authorised by the FCA as a full-scope UK Alternative Investment Fund Manager and manages a number of UK and non-EEA Alternative Investment Funds (AIFs). The Firm is also a UCITS manager and manages a number of UK UCITS. The Firm also has permissions to conduct additional business under the MIFID Directive and acts as delegate investment manager to Irish UCITS.
The Firm’s Policy is designed to be consistent with, and promote, sound and effective risk management and not encourage risk taking which is inconsistent with the risk profiles, rules or instruments traded by the AIFs or UCITS that it manages and of the Firm itself and complies with FCA’s rules.
Under the Policy, the Firm calculates and awards variable remuneration and benefits by reference to a series of metrics which include:
- the assessment of the performance of the individual concerned including financial as well as non-financial criteria;
- the assessment of the performance of the business unit or AIF or UCITS concerned; and
- the overall results of the Firm.
The level of importance of each criterion is determined in advance, and adequately balanced to take into account the position or responsibilities held by the individual concerned. The assessment of performance is also set in a multi-year framework appropriate to the life-cycle of the AIFs or UCITS managed by the Firm.
In accordance with FCA rules, the Policy also applies the remuneration rules applicable to the Firm in a way which is appropriate to its size, internal organisation and the nature, scope and complexity of its activities, as described above. In some circumstances and depending upon a range of criteria, firms may use the principle of proportionality to disapply the Pay-out Process Rules contained in FCA rules. The Pay-out Process Rules are the requirement to:
- pay a specified proportion of variable remuneration of Remuneration Code Staff (as defined below) in retained units, shares or other instruments;
- defer a specified proportion of variable remuneration of Remuneration Code Staff; and
- adjust the level of variable remuneration, or clawback variable remuneration already paid, due to performance adjustment.
The Firm’s approach to proportionality, in relation to the Pay Out Process Rules is kept under regular review, including review by the Firm’s Board on at least an annual basis. In addition, notwithstanding any right the Firm may have to dis-apply the Pay-Out Process Rules, the Firm has resolved on business grounds that it wishes to maintain commercial controls regarding variable pay which are designed to ensure that the interests of the Firm’s officers and staff are aligned to those of the Firm and its clients.
The above controls apply to the Firm’s Remuneration Code staff as defined below.
The Firm’s Remuneration Code Staff comprise the following:
- Senior Management;
- Staff responsible for heading the Portfolio Management, Risk Management, Administration, Marketing and Human Resources teams;
- Other risk takers such as any member of staff receiving total remuneration that takes them into the same remuneration bracket as Senior Management and whose professional activities have a material impact on the risk profiles of the Firm, the AIFs and the UCITS the Firm manages; and
- Where appropriate, categories of staff of entities to which portfolio management and/or risk management functions have been delegated by the Firm, whose professional activities have a material impact on the risk profiles of the AIFs and UCITS that the Firm manages.
The Policy is reviewed at least annually, taking into account the current and future risks and the cost and quantity of capital and liquidity required, having regard to the Firm’s financial forecasts. Changes are approved by the Firm’s Board and overseen by the Quilter Remuneration Committee.
Updated information on the Policy including information on how remuneration and benefits are calculated in the Firm are available free of charge on request by writing to Quilter Investors Limited, Millennium Bridge House, 2 Lambeth Hill, London, EC4V 4AJ.