MIFIDPRU Public Disclosure: Year ended 31 December 2023

Axebrook Capital LLP 

Year ending 31st December 2023 

1. INTRODUCTION AND REGULATORY CONTEXT 

Axebrook Capital LLP (or “Axebrook”, or “the firm”) is a limited liability partnership incorporated in England & Wales. The Firm was authorised and regulated by the Financial Conduct Authority (the “FCA”) as a MIFIDPRU Investment Firm Full Scope AIFM CPMI and is therefore subject to the requirements in MIFIDPRU as well as IPRU(INV) chapter 11. 

Axebrook provides the following services: 

  • Asset management (including portfolio management) 
  • Investment Advisory Services 
  • Managing an AIF 

The Firm provides these services to UK clients that are categorised as either professional clients or eligible counterparties. 

The Firm is categorized as a SNI MIFIDPRU investment firm by the FCA for capital purposes, and reports on a solo basis. The Firm’s MIFIDPRU 8 disclosure fulfils the Firm’s obligation to disclose to market participants’ key information on a firm’s remuneration policies and practices

In making the qualitative elements of this disclosure, the Firm is required to provide a level of detail that is appropriate to the Firm’s size and internal organisation, and to the nature, scope and complexity of its activities.

This disclosure is made annually on the date the Firm publishes its annual financial statements. As appropriate, this disclosure is made more frequently, for example if there is a major change to the Firm’s business model. There have been no significant changes since the previous disclosure.

2. REMUNERATION POLICIES AND PRACTICES

The Firm is subject to the Remuneration Code (the “Code”) for MIFIDPRU Firms as codified in Section 19G of the SYSC sourcebook of the Financial Conduct Authority handbook.

This disclosure sets out qualitative and quantitative information on the Firm’s remuneration processes and practices.

Qualitative Information

The Firm’s objectives are to implement and maintain a remuneration policy that supports a performance culture based on merit, rewarding excellent performance within the parameters of its regulatory obligations. The policy aims to blend Fixed and Variable Compensation in a manner that reflects the Firm’s values and also the value and responsibility of the individual’s role within the Firm whilst influencing appropriate behaviour, compliance with regulatory standards and risk management practice, and the need to pay due regard to the interests of the Firm’s clients and to treat them fairly.  

Governance 

Given the nature and small size of our business, remuneration for all employees is set by the Firm’s management body. The Firm ensures that staff who hold senior management functions are independent from the business functions they oversee and have the appropriate authority. They must be remunerated according to objectives linked to their role, independent of the performance of the business area they control.

The Firm also ensures that the remuneration of the senior officer in the risk management and compliance functions is directly overseen by the Governing Body.

These measures are to ensure we appropriately manage any conflicts of interest which may arise if other business areas have undue influence over the remuneration of staff in senior management functions.

Summary of how the Firm links pay and performance 

The available bonus pool for staff is determined by the overall profitability of the firm and the competitive
landscape for personnel in related businesses. The measure of performance is in part based on the returns generated by the Firm’s Funds.

Compensation comprises a mix of Fixed and Variable components and as such is designed to ensure adequate consideration of risk in remuneration decisions.

The following components of remuneration are regarded as being fixed:

  • Base salary / drawings
  • Employer pension contributions

The following components of remuneration are regarded as variable:

  • Discretionary bonus / profit allocation

Assessing Performance 

An individual’s performance is measured throughout the year based on the Governing Body’s perspective of how much that person’s work has contributed to the success of the firm. Success in this context will be measured by the Firm’s financial and investment performance, risk control, compliance and governance and client retention.

When the Firm is assessing individual performance to determine the amount of variable remuneration, it will consider both financial and non-financial criteria. As conduct is crucial to the compliance culture of the Firm, if an employee shows poor conduct, this may override their performance in financial areas. Conduct is therefore the biggest metric within non-financial considerations. Other non-financial metrics we may consider include:

  • the building and maintenance of positive customer relationships and outcomes; 
  • alignment with our strategy or values, for example by displaying leadership, teamwork or creativity; 
  • adhering to our Compliance Policies & Procedures; and 
  • meeting other non-financial targets relating to environmental, social and governance factors and diversity and inclusion.

Quantitative Information 

With respect to the financial year ended 31 December 2023, the total amount of remuneration awarded to all staff was £3,546,755. This figure includes fixed remuneration of £708,851 and variable remuneration of £2,837,904.

< Home