Overview

This policy outlines our firms approach to remuneration. The objective of our remuneration policy is to ensure that our firm does not remunerate or assess the performance of any of our employees in a way that conflicts with our duty to act in the best interests of our customers.

We will not make any arrangement by way of remuneration, sales targets or otherwise that could provide an incentive to our employees to recommend a product to a customer when our firm could offer a different product, which would better meet the needs of that customer.

Our firm maintains a separate conflicts of interest policy, which determines our overall approach to identifying, preventing and/or managing all types of conflicts including firm level arrangements and our firm’s requirements in relation to gifts and hospitality payments.

Scope of coverage

This policy applies to all employees whose remuneration may present the potential for conflict with the duty to act in the best interests of a customer. This will include all employees with an impact directly or indirectly on the services provided by our firm.

This will include but is not be limited to employees who:-

· sell products/services themselves to customers;

· are involved in the advice process; or

· are able to influence sales to customers, such as members of a compliance etc.

Oversight

Our firm’s senior management will have the overall responsibility to ensure that our firm operates remuneration practices that aim to ensure that the firm acts in the best interests of our firm’s customers at all times and in line with the FCA’s rules and guidance.

The senior management of our firm will be responsible for the day-to-day implementation of our remuneration policy and the monitoring of compliance risks related to this policy.

Our remuneration policy will be reviewed annually in accordance with SYSC 19G and this policy and its reviews will be conducted to ensure our firm’s remuneration practices, of any kind, does not affect our ability to ensure a sound capital base at all times.

Where necessary, our firm will undertake ad hoc reviews. This may be required as a result of internal monitoring, a change to regulations, following an independent review of our firm’s remuneration practices or any other relevant circumstances.