London Investment Management | Pillar 3 Discolsure

MIFIDPRU 8.6 Disclosure (Unaudited)

Scope and purpose

London Investment Management Ltd. is classified as a small and non-interconnected (SNI) MIFIDPRU Investment Firm and is therefore required under MIFIDPRU 8.6 to disclose information relating to remuneration policies and practices.

In accordance with these rules, the disclosures herein are appropriate to the size, internal organisation, nature, scope, and complexity of the Firm’s activities.

Approach to remuneration

Base salaries provide pre-determined, non-revocable compensation paid to individuals throughout the year, irrespective of Firm or individual performance. Base salaries and benefits constitute a significant proportion of the Firm’s total remuneration. This fixed element is based on the professional experience and responsibility within the Firm of an individual.

The Firm runs a discretionary bonus scheme that is based on individual performance as well as the Firm’s underlying profitability. The bonus does not form part of individual’s contractual remuneration. The size of the bonus pool is linked to the overall performance of the Firm. The employee incentive payment is linked to the contribution of the individual to such performance. Bonuses are discretionary and will diminish or disappear in the event of poor business or individual performance.

When considering individual performance, the Firm considers both financial and non-financial metrics. To not incentivise unacceptable risk taking, fixed remuneration comprises most staff compensation.

Objective of financial incentives

The objective of providing financial incentives is to promote behaviour that is aligned to the Firm’s long-term interests, strategic objectives, and ethical standards. Financial incentives are used to reward individual performance, as well as performance in excess of the staff member’s job description and terms of employment.

Governance and decision-making procedures

The Firm is required to implement and maintain remuneration policies, procedures and practices for all directors and employees that are consistent with and promote sound effective risk management.

The policy is intended to cover all aspects of remuneration and has been created in accordance with the MIFIDPRU Remuneration Code (SYSC 19G).

The remuneration practices and policies are intended to:

promote sound risk management practices in alignment with the Firm’s risk management principles;

discourage risk taking that is inconsistent with the Firm’s risk appetite or risk management policies and principles;

control fixed costs by ensuring that remuneration expense varies according to profitability and does not place undue constraints on the Firm’s ability to maintain its capital base;

link remuneration to the Firm’s financial and operational performance as well as individual performance;

provide competitive, but not excessive, levels of remuneration compared to peer Firms of appropriate size, scope, and complexity; and

promote a positive culture towards risk management and compliance.

The remuneration practices and policies are intended to support the Firm’s business strategy, long term interests and values, and to ensure that risk taking does not exceed the Firm’s tolerated level of risk.

Periodic benchmarking ensures that remuneration at individual level is not unreasonable or disproportionate to the amount, nature, quality, and scope of the work performed.

The remuneration policy outlines the criteria used to assess the performance of the Firm and of individual staff members. The Firm’s performance is assessed against its overall financial performance, as well as other measures such as new business gained, client satisfaction and employee retention rates.

In assessing the performance of individual staff members, the Firm takes into account financial and non-financial criteria. Non-financial criteria includes:

(a) measures relating to building and maintaining positive customer relationships and outcomes, such as positive customer feedback;

(b) performance in line with firm strategy or values, for example by displaying leadership, teamwork or creativity;

(d) achieving targets relating to:

(i) improving and streamlining operational procedures and processes; and

(ii) diversity and inclusion.

Remuneration components

Quantitative disclosures