1. Introduction

This document sets out the remuneration policy (the “Policy”) and practices of Keith Bayley Rogers & Co. Ltd (the “Firm”). The Firm recognises that remuneration is a key driver of behaviour.

The Financial Conduct Authority (“FCA”) has highlighted the following objectives:

– 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.

– Discourage behaviours that can lead to misconduct and poor customer outcomes.

The Firm has formulated the Policy with reference to the guidance set out by the FCA. The Policy considers 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.

2. Remuneration Code

As a MiFID investment firm that is prudentially regulated by the FCA in the UK, the Firm must comply with applicable remuneration requirements set out in the FCA Handbook.

The Firm adheres to the FCA’s Remuneration Code (the “Code”) as defined in the Systems and Controls Sourcebook of the FCA Handbook as laid out in SYSC 19G.

The Firm applies the Remuneration Code and guidance in a proportionate manner that reflects the size, internal organisation and nature of the Firm, and the scope and complexity of the activities the Firm undertakes and reviews this proportionate approach on at least an annual basis.

 
3. Core Firm Information

The Firm is a Small, Non-Interconnected Firm (“SNI”) which does not meet the conditions for extended requirements, which means the Firm must comply with only basic requirements.

The performance management process is carried out and administered by the Firm’s board of directors (the “Board”) and reviewed every year. 

4. Basic Remuneration Requirements

4.1 Policy

The Firm’s Policy has been created and is reviewed annually by Board. Its aims are to promote sound and effective risk management, to encourage responsible business conduct, to limit risk taking and avoid conflicts of interest, to align employee’s interests with the Firm’s long-term strategy and objectives, and to be gender neutral, in line with the Equality Act 2010.

The Policy is designed to align risk and reward, to ensure the capital base of the Firm is not put at risk by its remuneration incentives.

4.2 Governance and Oversight

The Board is responsible for overseeing the implementation of the Policy and ensuring its compliance with the Code.  One role of the Firm’s Board is to ensure the extent of the variable remuneration at the Firm cannot affect the Firm’s ability to ensure a sound capital base. The details of how this is achieved are to be found in 4.3 below.

The remuneration of senior staff in risk management and compliance functions is directly overseen by the Board.

4.3 Remuneration Structure

The Firm’s remuneration structure is designed to reward behaviours that promote positive non-financial outcomes for the Firm and to limit behaviours contrary to the Firm’s values. The remuneration structure is reviewed annually by the Board.

The Firm’s bonus scheme is a discretionary reward scheme and cannot be guaranteed nor considered as a contractual benefit as it is fundamentally based on the performance of the Firm as a whole. Bonuses are linked to both financial and non-financial criteria.  Bonuses will only be awarded where the firm is well above the minimum level necessary to maintain the prudential soundness of the firm.

The overall bonus pool and the bonuses of individuals are all subject to review and approval by the Board. The bonus pool and other individual bonuses will be adjusted as deemed necessary by the Board 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 key performance
indicators.

– Any conduct related matters that have occurred or are under investigation internally or externally.

– Any matters that adversely impact client outcomes.

– Any other factors that may publicly impact the Firm’s brand or reputation.

5. Bonus Scheme Participation

Bonus scheme eligibility is discretionary and is dependent on current headcount, length of service and position within the company.

Specific bonus agreements may be outlined within individual contracts.

6. Standard Remuneration Requirements

6.1 Performance Assessment and Remuneration

If a staff member is eligible, performance bonuses are paid based on a combination of the performance of the individual, the relevant business unit and the Firm. Staff are assessed under the Firm’s performance management process on an ongoing basis.

6.2 Non-Performance-Related Variable Remuneration – i.e., Guarantees 

The firm does not currently offer non-performance related variable remuneration.