MIFIDPRU 8 Disclosure
Remuneration Policies and Practices
As a MIFIDPRU investment firm, Astaris Capital Partners LLP, the (“Firm” or “Astaris”) must establish, implement and maintain gender neutral remuneration policy and practices that are appropriate and proportionate to the nature, scale and complexity of the risks inherent in the business model and the activities of the Firm. Our remuneration policy and practices are gender neutral and do not discriminate employees on the basis of gender or other characteristics.
The Firm is subject to both the MIFIDPRU Remuneration Code and the AIFM Remuneration Code. We, therefore, commit to complying with the most stringent requirement in instances where the requirements differ, and we can only comply with one. The Firm, therefore, considers which requirement is the most stringent on a provision-by-provision basis.
The Firm’s performance period is from 01 April 2022 to 31 March 2023.
The Firm has adopted a Remuneration Policy that complies with the requirements of Chapter 19G of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook.
Approach to remuneration
The Firm’s remuneration approach is designed to support individual and corporate performance, encourage the sustainable long-term financial health of the business and promote sound risk management for the success of the Firm and to the benefit of its customers, counterparties and the wider market. Our remuneration approach promotes long-term value creation through transparent alignment with the agreed corporate strategy.
The Board believes the Firm’s remuneration structure is appropriate for the business and the industry it operates in and is efficient and cost-effective in delivering its long-term strategy.
Undeserved and excessive remuneration sends a negative message to all stakeholders, including the Firm’s workforce, and causes long term damage to the Firm and its reputation.
Financial incentives objectives
The objectives of the Firm’s remuneration practices are as follows:
- The Firm undertakes to reward all employees fairly, regardless of job function, race, religion, colour, national origin, sex, sexual orientation, marital status, pregnancy, disability or age;
- It is the policy of the Firm to operate competitive remuneration policies to attract, retain and motivate an appropriate workforce for the Firm;
- The Firm is also committed to ensuring that its remuneration practices encourage high standards of personal and professional conduct, support sound risk management and do not encourage risk taking that exceeds the level of tolerated risk of the Firm, and are aligned with the Firm’s regulatory requirements;
- Rewards for all staff will be aligned to financial and non-financial performance criteria and risk profile, and in all cases will be in line with the business strategy, objectives, values, culture and long-term interests of the Firm;
- The Firm will not allow any unfair or unjust practices that impact on pay;
- The Firm undertakes that it will not award remuneration using vehicles or methods the aim of which is to attempt to avoid application of the relevant FCA’s Remuneration Code.
The Firm uses, amongst others, the following financial incentives:
- profit shares;
- salary raises;
- sale commission;
- professional development opportunities;
Our financial incentives are designed to:
- raise employee satisfaction;
- recognise individual performance;
- attract and retain talent;
- encourage collaborative teamwork; and
- motivate staff to achieve Firm-wide objectives.
The The Governing Body is responsible for the Firm’s remuneration policy.
As a SNI, the Firm is not required to establish a Remuneration Committee. Given the size, internal organisation and the nature, scope and complexity of the activities of the Firm it has not formed a Remuneration Committee. Therefore, the Remuneration policy’s supervisory function is undertaken by the Firm’s Board.
The Board is responsible for reviewing and approving remuneration, and to ensure remuneration policies across the Firm are consistent with the promotion of effective risk management. The Board is responsible for reviewing and approving salary amendments and the Firm’s bonus pool arising from the annual compensation review, with reports made to the Board as required.
The Board meets regularly and is composed of:
- Martin Beck
- Bjorn Bischoff
- Robert Pohlhausen
- Geoffrey Haffner
Components of remuneration
The Firm makes a clear distinction between the fixed and variable remuneration.
Fixed remuneration primarily reflects a staff member’s professional experience and organisational responsibility as set out in the staff member’s job description and terms of employment; and is permanent, pre-determined, nondiscretionary, non-revocable and not dependent on performance.
Variable remuneration is based on performance and reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment. In exceptional cases, variable remuneration is based on other conditions. Variable remuneration includes discretionary pension benefits.
The Firm will ensure that the fixed and variable components of an individual’s total remuneration are appropriately balanced. In determining this balance, the Firm considers the following factors:
- The Firm’s business activities and associated prudential and conduct risks;
- The role of the individual in the Firm;
- The impact that different categories of staff have on the risk profile of the Firm or of the assets it manages;
- No individual must be dependent on variable remuneration to an extent likely to encourage them to take risks outside the risk appetite of the Firm;
- It may be appropriate for an individual to receive only fixed remuneration, but not only variable remuneration; and
- Variable remuneration must not affect the Firm’s ability to ensure a sound capital base.
When assessing individual performance to determine the amount of variable remuneration to be paid to an individual, the Firm takes into account financial as well as non-financial criteria. Non-financial criteria should:
- Form a significant part of the performance assessment process;
- override financial criteria, where appropriate;
- include metrics on conduct, which should make up a substantial portion of the non-financial criteria; and
- include how far the individual adheres to effective risk management and complies with relevant regulatory requirements.
Financial and non-financial performance criteria
The Firm must take into account both financial and non-financial criteria when assessing the individual performance of its staff. This aims not only to discourage inappropriate behaviours but also to incentivise and reward behaviour that promotes positive non-financial outcomes for the Firm.
When considering financial performance the Firm will take into consideration the performance of:
- The Firm overall;
- The business unit; and
- The individual
The Firm uses the following non-financial performance criteria:
- measures relating to building and maintaining excellent service for all Astaris’ customers;
- performance in line with firm strategy or values, for example by displaying leadership, teamwork or creativity;
- adherence to the firm’s risk management and compliance policies.
Quantitative Remuneration Disclosure
During the financial year between 1 April 2022 and 31 March 2023, the total amount of remuneration awarded to all staff was £2,485,145. The proportion of the fixed remuneration of these staff was £1,003,647 and the proportion of variable remuneration of these staff was £1,481,498.
For these purposes, the term ‘staff’ should be interpreted broadly to include, for example, employees of the firm itself, partners or members (in the case of partnership structures), employees of other entities in the group, employees of joint service companies, and secondees.