MiFIDPRU Notice

MiFIDPRU 8.6 Disclosure

(Based on audited financial statements for the year ending 2024)

Scope and Purpose

This disclosure relates to Wealthfusion Limited, which 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 the 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 staff members throughout the year, irrespective of Firm's or individual's performance. Base salaries and benefits constitute the 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 performance bonus scheme that is based on individual performance as well as the Firm's underlying profitability. The bonus does not form part of an individual's contractual remuneration. The size of the bonus pool is linked to the overall performance of the Firm. The staff member bonus 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. Non-financial criteria includes, but is not limited to:

  • measures relating to building and maintaining positive client relationships and outcomes such as positive client feedback;
  • performance in line with the firm's strategic vision and values (ie. displaying leadership, teamwork, active participation within strategic project workstreams);
  • adherence to the firm's risk management and compliance policies;
  • participation within the firm's corporate social responsibility (CSR) activities;

To not incentivise unacceptable risk taking, fixed remuneration is the key element of staff member 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-Marking Procedures

The Firm is required to implement and maintain remuneration policies, procedures and practices for all directors and staff members 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 procedures;
  • 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 as well as 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 levels is not unreasonable or disproportionate to the amount, nature, quality and scope of the work performed. The Remuneration Committee 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.

Remuneration Components

The Firm has at its disposal four categories for rewarding staff members, one of which is fixed (ie. base salary) and three are considered variable (ie. discretionary performance bonus, phantom stock award and equity shares). When identifying individuals as 'staff' this has been interpreted broadly in line with SYSC 19G.1.24G.