MIFIDPRU 8 Disclosure

Greentrail Partners LLP
MIFIDPRU 8 Disclosure
May 2024

Introduction

The Financial Conduct Authority (“FCA” or “regulator”), in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Greentrail Partners LLP (“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.

The firm 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.

This document has been prepared by the firm in accordance with the requirements of MIFIDPRU 8 and is verified by the Partners. Unless otherwise stated, all figures are as at the Firm’s financial year-end, being 31 March 2024.

Remuneration Policy and Practices

Overview

As an SNI MIFIDPRU Investment Firm, the firm 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”)). GP, as an alternative investment fund manager, is also classified as a collective portfolio management investment firm (“CPMI firm”) and as such is also subject to the AIFM Remuneration Code (SYSC 19B). 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 objective of the firm’s remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients.

In addition, the firm recognises that remuneration is a key component in how the Firm attracts, motivates, and retains quality staff and sustains consistently high levels of performance, productivity, and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and provide its greatest competitive advantage.

The firm is committed to excellence, teamwork, ethical behaviour, and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude, and results.

Characteristics of the Firm’s Remuneration Policy and Practices

Remuneration at the firm is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial performance and the financial and non-financial performance of the individual in contributing to the Firm’s success. All staff members are eligible to receive variable remuneration.

The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.

Governance and Oversight

The management committee of the firm is responsible for setting and overseeing the implementation of the firm’s remuneration policy and practices. In order to fulfil its responsibilities, the management committee:

• Is appropriately staffed to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital, and liquidity.
• Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm.
• Ensures that the Firm’s remuneration policy and practices take into account the the long-term interests of shareholders, investors, and other stakeholders in the Firm.
• Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values, and interests of the Firm and of its clients.

The firm’s remuneration policy and practices are reviewed annually by the management committee.

Quantitative Remuneration Disclosure

For the financial year to 31 March 2024, the total amount of remuneration awarded to all staff was £467k, of which £286k comprised the fixed component of remuneration, and £186k comprised the variable component. For these purposes, ‘staff’ is defined broadly, and includes partners and employees of the Firm.