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MIFIDPRU 8 Disclosure

 Clerville Investment Management LLP –MIFIDPRU 8 Disclosure

Financial Year 31 December 2022

1. Introduction

The Financial Conduct Authority (“FCA”) in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Clerville Investment Management LLP(”CIM”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8” or the “public disclosures requirements”) sets out public disclosure obligations with which the Firm must comply, further to those prudential requirements.

CIM is classified under MIFIDPRU as a small and non-interconnected investment firm (“SNI MIFIDPRU investment firm”). As such CIM has produced this public disclosure in line with the rules and requirements of MIFIDPRU 8.6, as applicable to SNI firms without additional tier 1 instruments in issue.

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2. Remuneration Policy

As an SNI MIFIDPRU Investment Firm, CIM is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). The purpose of the remuneration requirements is to:

  • Promote effective risk management in the long-term interests of CIM and its clients;

  • Ensure alignment between risk and individual reward;

  • Support positive behaviours and healthy firm cultures; and

  • Discourage behaviours that can lead to misconduct and poor customer outcomes.

 

The objective of CIMs remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients.

In addition, CIM recognises that remuneration is a key component in how the Firm attracts, motivates and retains quality staff and sustains consistently high levels of performance, productivity and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and greatest competitive advantage.

CIM is committed to excellence, teamwork, ethical behaviour and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude and results.

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3. Characteristics of CIMs Remuneration Policy and Practices

Remuneration at CIMis made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the firm’s financial performance, and the financial

and non-financial performance of the individual in contributing to CIMsuccess. All staff members are eligible to receive variable remuneration.

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4. Governance and Oversight

CIM does not have a separate remuneration committee. The responsibility for setting and overseeing the implementation of CIM’s remuneration policy and practices rests with the Partners. To fulfil its responsibilities, the partners

  • Can exercise competent and independent judgment on remuneration policies and procedures;

  • Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm;

  • Ensures CIM’s remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors and other stakeholders in the Firm; and

  • Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values and interests of the Firm and of its clients. CIM’s remuneration policy and practices are reviewed annually by the Partners.

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5. Quantitative Remuneration Disclosure

For the financial year 1 January to 31 December 2022, the total amount of remuneration awarded to all CIM staff was £2,280,352of which £1,355,945 comprised the fixed component of remuneration, and £924,407comprised the variable component.

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