1. Introduction
This disclosure sets out the remuneration policies and practices of Hengistbury Investment Partners LLP (“the Firm”) for the financial year ended 31 December 2023, in accordance with the requirements of MIFIDPRU 8 and the FCA’s Remuneration Code as applicable to MIFIDPRU investment firms.
The Firm is classified as a non-SNI (Small and Non-Interconnected) MIFIDPRU firm. As such, the Firm is subject to basic remuneration requirements under MIFIDPRU 7 and is not required to apply the full suite of variable remuneration requirements applicable to larger firms.
2. Governance
The Firm’s remuneration policy is determined and overseen by the members of the LLP in accordance with applicable regulatory requirements. Given the size and nature of the Firm, a separate remuneration committee has not been established; remuneration decisions are made by the Firm’s management with independent oversight applied proportionately to the Firm’s scale.
The remuneration policy is reviewed at least annually to ensure it remains appropriate and consistent with the Firm’s risk profile, strategy and applicable regulatory requirements.
3. Fixed and Variable Remuneration
3.1 Fixed Remuneration
Fixed remuneration reflects the relevant experience, skills, seniority and responsibilities of members and employees. It is set at a level that is appropriate to attract and retain qualified staff and is not contingent on performance.
3.2 Variable Remuneration
Variable remuneration, where awarded, is discretionary and determined with reference to the Firm’s overall financial performance, individual contribution, and risk management outcomes. Variable remuneration is not guaranteed and is not structured in a manner that incentivises excessive risk-taking.
The Firm ensures that the ratio of variable to fixed remuneration is set at a level appropriate to allow the Firm to operate a fully flexible bonus policy, including the possibility of paying no variable remuneration where warranted.
4. Risk Alignment
The Firm’s remuneration structure is designed to be consistent with and promote sound and effective risk management. Specifically:
- Remuneration is not structured in a way that conflicts with the Firm’s obligation to act in the best interests of its clients;
- Performance assessments take into account qualitative as well as quantitative measures, including adherence to risk management policies and regulatory requirements;
- The Firm does not reward risk-taking above levels it considers appropriate;
- Guaranteed variable remuneration is not awarded except in limited circumstances relating to recruitment, and only for the first year of engagement.
5. Quantitative Disclosure
In accordance with applicable proportionality provisions, the Firm discloses aggregate information on remuneration. The Firm does not identify individuals by name given the small size of the firm and the need to protect personal data in accordance with UK GDPR.
Quantitative disclosure in respect of the financial year ended 31 December 2023 is set out in the Firm’s annual report and accounts filed at Companies House.