North Rock Capital Management (UK) LLP
MIFIDPRU 8 Disclosure for the period 1 July 2022 - 30 June 2023
North Rock Capital Management (UK) LLP (“the Firm”) is an investment management firm authorised and regulated by the Financial Conduct Authority (“FCA”) as a MIFIDPRU Investment Firm. The Firm is categorised under the FCA prudential regime for MiFID investment firms (“MIFIDPRU”) as a Small Non-Interconnected Firm (“SNI”).
The Firm has produced this disclosure in relation to its remuneration policies and practices, per its obligations under Chapter 8 of MIFIDPRU. It has been prepared based on the Firm’s audited financial statements covering the accounting period 1 July 2022 to 30 June 2023. This disclosure has been made according to the size and internal organization of the Firm’s business, and to the nature, scope and complexity of its activities.
Significant changes since the prior disclosure period
There have been no significant changes to the information disclosed since the Firm’s last disclosure period.
Remuneration policy and practices
The Firm is subject to the MIFIDRPRU Remuneration Code contained within SYSC 19G of the FCA Handbook (“the Remuneration Code”). The overall aim of the Remuneration Code is to:
-
promote effective risk management in the long‑term interests of the firm and its customers
-
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.
Per SYSC 19G.2 the Firm maintains remuneration policies and practices that:
-
are aligned with the business strategy, objectives and long-term interests of the firm;
-
are consistent with and promote sound and effective risk management, and
-
contain measures to avoid conflicts of interest, encourage responsible business conduct and promote risk awareness and prudent risk taking.
The Firm’s Senior Managers Committee is the governing body responsible for the development and adoption of the Firm’s Remuneration Policy. The Senior Managers Committee is also responsible for overseeing the implementation of the Remuneration Policy. The Firm does not have a Remuneration Committee. All staff are eligible to receive variable remuneration.
The Firm remunerates its staff in a manner designed to attract the best possible candidates, and to support the Firm’s strategy and objectives of maximising persistent risk-adjusted investment returns for its client and for underlying investors, whilst ensuring high standards of compliance and conduct consistent with the Firm’s culture and values. The Firm also pays fixed and variable remuneration to staff in a manner designed not to introduce liquidity or other prudential risks to the Firm. The long-term success of the Firm is supported by meeting these objectives.
Variable remuneration is a key part of the Firm’s remuneration structuring, and fixed to variable remuneration metrics are tailored to individual staff members’ roles. An individual’s performance is important to the level of variable remuneration awarded, with separate qualitative and quantitative performance metrics applying as relevant to different roles. The Firm in practice operates a single business unit - portfolio management - however, individual teams’ performances within the business unit are relevant. This is the case especially for portfolio management staff members for whom the pool of variable remuneration is based on positive investment performance by their relevant team against the Firm’s relevant risk-management metrics. The Firm’s overall performance is also relevant and impacts on the amount of variable remuneration available to be paid to staff.
For the financial year 1 July 2022 to 30 June 2023, the total amount of remuneration awarded to all staff was GBP 18,631,036, of which GBP 7,647,053 was fixed remuneration and GBP 10,983,983 was variable remuneration. “Staff” was interpreted to include all employees and members of the Firm.