Remuneration Policy

Reference date: 31st March 2022

Qualitative disclosures

This Policy applies to all of Thornbridge’s staff including the management team. The Policy covers all aspects of remuneration. Thornbridge has determined that, in accordance with FCA guidance, the relevant requirements of SYSC 19G shall be applied in a manner that is proportionate to our size, internal organisation and the nature, scope and complexity of our activities as well as our business strategy, objectives and long-term interests of the Firm.

The Policy is designed to ensure that Thornbridge’s remuneration policies, procedures and practices are consistent with and promote sound and effective risk management and do not encourage excessive or inappropriate risk taking which is inconsistent with the risk profiles of Thornbridge’s funds.

The governance of remuneration is managed through The Management Committee which oversees remuneration policies and procedures.

All staff are covered by the remuneration policy.

Key characteristics of Thornbridge’s remuneration policy

Thornbridge takes account of the need to ensure that fixed and variable components of total remuneration are appropriately balanced. All remuneration paid to a staff member is clearly categorised as either fixed or variable.

When determining what is an appropriate balance, Thornbridge considers:

  • Its business activities and associated prudential and conduct risks;
  • The role of each individual in the firm.

It may be appropriate for some staff to receive only fixed remuneration. Thornbridge does not consider it appropriate for any individual to receive only variable remuneration.

Fixed remuneration

In setting and reviewing fixed remuneration, Thornbridge takes account of the staff member’s professional experience and organisational responsibility as set out in their job description, Thornbridge Responsibilities Map and terms of their employment.

Variable remuneration

The Management Committee annually reviews the methods for calculating variable remuneration.

All bonuses awarded from these pools are discretionary. Bonuses are allocated based on performance of the overall business, the performance of specific business units and individual performance, taking into account consideration of financial and non-financial criteria. Non-financial criteria include conduct, building and maintaining positive customer relationships and outcomes, adherence to effective risk management, compliance with relevant regulatory requirements and achieving targets relating to ESG and diversity & inclusion. Non-financial criteria make up a substantial portion of variable compensation and override financial criteria where appropriate.

As Thornbridge is an Investment management company variable remuneration may apply to returns on investments made by the staff.

Quantitative disclosures

Total amount of remuneration awarded to all staff in the FFY 2021-2022:

Fixed remuneration : £1,021,840

Variable remuneration : £57,500