MIFIDPRU Disclosure

Axebrook Capital LLP 

Year ending 31st December 2022 


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 on 10 November 2021 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 Investment Firms Prudential Regime (IFPR) is the FCA’s new prudential regime for MiFID investment firms which aims to streamline and simplify the prudential requirements for UK investment firms. The IFPR came into effect on 1st January 2022, and its provisions apply to Axebrook as an FCA authorised and regulated firm. 

The public disclosure requirements of IFPR are set out in MIFIDPRU 8, replacing the previous Pillar 3 requirements under BIPRU 11. 


The disclosures in this document relate to Axebrook Capital LLP. Axebrook can be classified as a SNI firm given it does not exceed any of the thresholds set out in MIFIDPRU 1.2.1 R. 

The Firm is required to disclosure the following information: 

  • Policy and practices (MIFIDPRU 8.6) 
  • Provision of quantitative and qualitative disclosures in respect of the firm’s remuneration arrangements 

The information is provided as at 31 December 2022. 


Approach to remuneration 

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. 


The Firm’s Remuneration Policy has been approved by the Firm’s Governing Body after taking advice from our Compliance Officer. The Compliance Officer is responsible for implementing and monitoring the remuneration policy. 

Given the size, internal organisation and the nature, scope and complexity of the activities of the Firm, it has not established a Remuneration Committee. 

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. 

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. 

Components of remuneration 

The following components of remuneration are regarded as being fixed: 

  • Base salary / drawings 
  • Employer pension contributions 

The following components of remuneration are regarded as being variable: 

  • Discretionary bonus / profit allocation 
Fixed remuneration Variable remuneration 
All Staff £420,000 £1,198,000 
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