FCA Remuneration Policy

The Financial Conduct Authority (“FCA” or “regulator”) in the Prudential source book for MiFID Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Igloo Investment Management Limited (“Igloo” or the “Firm”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance with which the Firm must comply, further to those prudential requirements.

 Igloo is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices.

The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture and to assist stakeholders in making more informed decisions about their relationship with the Firm.

Asan SNI MIFIDPRU Investment Firm, Igloo is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). The purpose of the remuneration requirements is to: 

• Promote effective risk management in the long-term interests of the Firm and its clients;
• 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. 

The aim of the firm’s remuneration policy is to ensure that it is risk-focused and is consistent with and promotes effective risk management, thereby not exposing the company, management, employees nor clients to excessive risk. 

In general terms, the remuneration of the firm’s management and employees comprises base salary and a fixed percentage contribution to the individual’s personal pension. Any performance-related pay (if and when any such would arise) is not guaranteed. In the event that any performance related pay did arise, it would be discretionary, variable and based on a combination of the assessment of the performance of: (a) the individual; (b) the business unit concerned; and (c) the overall results of the firm and the group; and (2) when assessing individual performance, financial as well as non-financial criteria are taken into account. 

The remuneration policy of the company is consistent with that of the parent company and the group.