SL Investment Management MiFIDPRU Disclosure 31 December 2023
Introduction
SL Investment Management Limited (“SL”, the “Firm” or “we”) is a MiFID investment firm authorised and regulated by the Financial Conduct Authority (FCA). We are required to comply with the disclosure requirements under the Investment Firms Prudential Regime (IFPR), which is set out in the FCA Handbook MIFIDPRU 8.
For the purpose of the prudential regulations, we are classified as an SNI (small and non-interconnected) firm and are subject to the basic requirements to provide a level of detail in our disclosures that is appropriate to our size and internal organisation, and to the nature, scope, and complexity of our activities. We are required to comply with the MIFIDPRU Remuneration Code under IFPR, which aims to ensure that we have risk-focused remuneration policies that are consistent with and promote sound and effective risk management in the long-term interests of the Firm and our clients and do not expose the Firm or our clients to excessive risk.
Remuneration Disclosures
Our approach and objectives
We have formulated the approach in our remuneration policy and practices with reference to the guidance set out by the FCA. We consider the appropriate balance between fixed and variable remuneration as well as the constraints in place to avoid a conflict of interest between staff incentives and the best interests of clients.
Governance and decision-making procedures
The management body of the Firm is responsible for overseeing the implementation of our remuneration policy and ensuring our compliance with the MIFIDPRU Remuneration Code.
One role of the management body of the Firm is to ensure the extent of the variable remuneration at the Firm cannot affect the Firm’s ability to maintain a sound capital base. The management body of the Firm is responsible for overseeing the performance management process; reviewing and approving the remuneration policy, variable remuneration pool and caps, eligibility of participation in variable remuneration schemes, as well as the approval of variable remuneration awarded to individuals.
We assess our staff members under our performance management process on an ongoing basis with an annual performance assessment outcome being used as a contributing factor in the determination of remuneration.
The remuneration of senior staff in risk management and compliance functions is directly overseen by the management body of the Firm. Any remuneration to staff with control functions is awarded according to objectives linked to their functions and remains independent from the business units they oversee.
No variable remuneration is awarded to members of the management body who do not perform any executive function in the Firm.
The Firm’s remuneration policies and practices are developed in consultation with our external consultants.
Key characteristics of remuneration policies and practices
All staff receive fixed remuneration in the form of base salary and are considered for discretionary variable remuneration in the form of a bonus where eligible.
Base Salary
We review the base salary of our staff members on an annual basis by considering factors such as market information and individual performance.
Bonus
The Firm’s bonus scheme is a discretionary reward scheme determined by the SL Board and ensures that the aggregate spend on compensation is directly linked to the Firm’s financial performance. All bonuses are dependent on the firm’s overall financial result to ensure a sound capital base.
On an individual level, the scheme is designed and linked to both financial and non-financial criteria, rewarding behaviours that promote positive non-financial outcomes for the firm and limiting eventual behaviours contrary to the firm’s values.
The bonus pool and other individual bonuses will be adjusted as deemed necessary by the management body of the Firm in consideration of the following:
- Any compliance or regulatory issues that have occurred or are under investigation internally or externally;
- Any persistent or significant breaches in either financial or non-financial KPIs;
- Any conduct related matters that have occurred or are under investigation internally or externally;
- Any matters that adversely impact client outcomes; and
- Any other factors that may publicly impact the Firm’s brand or reputation.
Control function staff are independent of the business units they oversee and are remunerated in line with the achievement of the objectives of their functions. The determination of the level of remuneration of such staff is independent of the performance of the business areas they oversee.
Quantitative disclosures
For the financial year ending 31 December 2023, the amount of remuneration awarded is as follows:
| Total remuneration (£000) | 2,078 |
|---|---|
| Fixed remuneration | 1,432 |
| Variable remuneration | 646 |
| Headcount | 30 |
