Last updated: October 2022
Background
This disclosure is designed to provide information on Par Fund Management Limited ("PFML") remuneration policies and practices. PFML is required to comply with the Remuneration Code requirements within the FCA’s handbook of rules and guidance which are equivalent to the Alternative Investment Fund Managers Directive (AIFMD) and Markets in Financial Instruments Directive (MiFID II). The FCA’s Remuneration Code requirements introduce the concept of proportionality which applies the Code to the extent that it is appropriate to a firm’s size, internal organisation (including legal structure) and the nature, scope and complexity of its activities.
PFML falls into the category of a Small Non-Interconnected (SNI) Firm therefore is only subject to the basic Remuneration Code requirements.
Please note that although PFML is the regulated entity, all employees are contracted with Par Equity Holdings Limited ("PEHL") which is the holding company for the group, collectively "Par Equity". No regulated activities are undertaken by PEHL.
Application
Par Equity endeavours to reward partners and staff fairly and appropriately for their contribution towards the success of the business and level of service and performance delivered to its clients.
The remuneration policy is designed to be consistent with and promote sound and effective risk management and should not encourage excessive risk-taking that exceeds Par Equity's risk tolerance. It is designed to be in line with Par Equity's strategy, risk profile and risk management practices, as well as our values and the long-term interests of Par Equity and its clients. This policy has been designed to avoid conflicts of interest and is subject to independent review by our Compliance Team and external Compliance Consultants. Par Equity achieves this by reviewing the remuneration of all staff annually, taking into consideration individual performance throughout the period under review and market practise for the role being undertaken. In addition, bonus arrangements are reviewed periodically to ensure their effectiveness.
The process for calculating bonuses and agreeing targets with individuals is also reviewed annually to ensure that the process is appropriate, fair and consistent across all employees.
Governance
The PFML Board oversees the remuneration process. In addition, the PFML Board approves all policies and processes relating to staff remuneration within the firm. These are reviewed annually, unless there's a material change within the firm which would impact the process.
Ultimately, the Partners give final approval for the recommendations on levels of salary increase and bonus awards made during the firm's annual review process. When doing so, the Partners take into consideration the general risks and parameters affecting the firm’s business and the measures taken across the business to ensure that the remuneration awards and parameters do not conflict with the firm's long term aims and the best interests of its clients.
Salary / Bonus Review Process
The salary review process is largely driven by the individual performance, the profitability and performance of the firm and the movement in salary levels for the relevant job match within independent survey data obtained by Par Equity. Independent advice on various remuneration issues and best practice is also received periodically by external consultants. Par Equity also pays performance related bonuses to staff. These are largely dependent on the performance of the individual and the firm's profitability.
As a SNI firm we must ensure fixed and variable pay is determined in a way that balances financial and non-financial performance, maintains control function independence and is sustainable and affordable for Par Equity.
