The FCA has amended the Prudential Sourcebook for Banks, Building Societies and Investment Firms (BIPRU), and specifically BIPRU 11, to now include a requirement for disclosure of the Firm’s approach to linking remuneration to risk.
As a BIPRU firm we can adopt a proportioned approach to our Remuneration Policy. The Remuneration Scheme does not incentivise the employees to take inappropriate risks. We have considered the Firm’s individual needs on an ongoing basis and, where appropriate, disapplied certain provisions in accordance with FCA and CEBS/EBA guidance. The Firm will review any provisions which have been disapplied on at least an annual basis, to ensure that it continues to be appropriate for the Firm not to apply such provisions.
The Decision Making Process
On grounds of proportionality Omba’s Board of Directors also serve as the remuneration committee. The Board of Directors decides the Firm’s tolerance to risk – those risks it will accept and those it will not take in the pursuit of its goals and objectives. In addition, the Board of Directors ensures that the Firm has implemented an effective, ongoing process to identify risk, to measure its potential impact against a broad set of assumptions and then to ensure that such risks are actively managed.
The Link between Pay and Performance
Overall remuneration may include an annual incentive compensation reflecting individual performance and responsibility, both short-term and long-term, as well as the Firm’s overall performance.
The Firm ensures that it attracts suitably experienced and qualified individuals, whilst ensuring they remain independent from the business areas they oversee, by remunerating these individuals with a higher ratio of fixed to variable remuneration.
The award of incentive compensation is a qualitative decision where employee and supervisory input are significant components. There is no compensation linked to sales of any product.
The Firm’s employment contracts are sufficiently flexible to allow the Firm to vary the date of any variable remuneration payments or cease to make any such payment. The Firm ensures that any payment of variable remuneration only occurs following risk adjustments to profits and where the Firm is at risk of being unable to maintain a sound capital base.
The code staff of the Firm are the Directors, the investment team, the client executives and the Compliance Officer.
Quantitative Remuneration Data
Owing to the relative size and complexity of the Firm’s business the aggregate quantitative information on remuneration, broken down by 1) business area; and 2) by senior management and members of staff whose actions have material impact on the risk of the Firm, is the same.