Remuneration Policy Summary
In accordance with the central Bank of Ireland's AIF Rulebook, AIFMs are required to have a remuneration policy that is consistent with The European Securities and Markets Authority's (ESMA) Guidelines on sound remuneration policies under the AIFMD (ESMA/2013/232). The Firm has a remuneration policy which is consistent with, and seeks to promote, sound and effective risk management and not to encourage risk-taking which is inconsistent with the AIFM's risk profile or the risk profiles of the AIFs that the AIFM manages and with the AIFM's approach to integrating and managing sustainability risk, if applicable.
The Firm's remuneration policy applies to senior management, staff engaged in control functions and risk takers whose professional activities have a material impact on the risk profile of the Firm and the funds it manages, and any other staff receiving total remuneration that takes them into the same remuneration bracket as senior management.
Under the ESMA guidelines the Firm has determined that it is not a ‘significant firm’ and consequently has not set up a remuneration committee; however, the Firm's governing body undertakes this role, in conjunction with the TCI Group senior management responsible for remuneration oversight. The decisions on setting remuneration are based on, amongst other things, risk management, supporting business strategy, objectives, values and interests and avoiding conflicts of interest, governance, control functions, and measurement of performance.
The Firm's governing body and TCI Group more broadly consider remuneration in the context of a wider agenda including retention, recruitment, motivation and talent development and the external market environment. It also receives updates on regulatory developments and general remuneration issues, as well as market and bench marking data.
Information on the link between Pay and Performance
The various components of total remuneration (which comprise base salary and variable bonus) are considered and are balanced appropriately having regard to the overall Firm and Group performance and fund performance.
Group and Firm performance and the input of the individual are the significant contributors to the determination of variable bonus awards. The principal objective in determining variable bonus awards is to reward individual contribution to the Firm whilst ensuring that such payments are warranted given business results. In this context performance can include financial and non-financial measures, risk measures and other relevant factors.
There is a focus on differentiation so that any rewards are determined according to the contribution of individuals. Bonus pools and individual awards are subject to the discretion of the board of directors and it is possible that in any year no variable bonus will be awarded, either at all, or to particular individuals.