Equities First (London) Limited’s Remuneration Statement
Equities First (London) Limited’s (the “Company”) pays all its staff remuneration which comprises a fixed element and can also include a variable element. An employee’s fixed element of their remuneration is based on pre-determined criteria. It is non-discretionary, transparent, permanent for the year and subject to an annual review, whereby any possible increase is assessed.
The fixed remuneration reflects a staff member’s professional knowledge and experience, their skills, the requirements of the particular role for which they are employed, their qualifications, and his/her organisational responsibilities as set out in the staff member’s job description and terms and conditions of employment.
The Company’s variable remuneration for sales staff can include commission and is the portion of compensation determined by the employee’s sales performance throughout the year. This is based on a percentage of sales generated and is over and above and not tied to the fixed remuneration which is payable regardless of the sales volume generated. Sales staff can also receive an annual discretionary bonus which also forms part of their variable remuneration.
All non-sales staff receive fixed salaries, but do not receive any commission. They can however receive variable remuneration in the form of an annual discretionary bonus. There are no staff members paid only commission/variable remuneration, and fixed remuneration levels are set at levels sufficient to ensure there should be no dependency by employees on their receiving variable remuneration in order to be able to live.
Annual reviews are in place to assess whether an individual has achieved their goals & objectives; met the core competencies required in their particular role; undertaken all required training (particularly regulatory training), and assess any future development needs. The annual reviews are in compliance with the FCA requirements and include an assessment of fitness & propriety for roles that fall under the Senior Managers & Certification Regime (SMCR) – this includes all sales staff.
The Company deems the following non-financial qualitative metrics to be relevant to its strategic objectives and therefore includes them in the annual review criteria for individuals:
- meeting the Company’s regulatory obligations (such as treating clients fairly; no upheld complaints; compliance with any stipulations set by the Compliance Officer, etc);
- observing and adhering to the firm’s risk management and compliance policies and systems and controls that are in place; and
- observing and adhering to the compliance and governance procedures that are in place.
- Not having been subject to any disciplinary action or breached any of the Financial Conduct Authorities (FCA) conduct rules
The Company does not discriminate against anyone on the grounds of any of the following characteristics (without limitation): age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion/belief, sex (gender) and sexual orientation.
The Company’s compliance consultants provide comments and input at least on annual basis into the Company’s remuneration policy to ensure it is balanced and proportionate; does not lead to any undue risk taking by any employees; and that it is compliant with FCA relevant requirements.
The Company’s remuneration policy must be clear and documented, and appropriate and proportionate to nature, scale and complexity of the risks inherent in the Company’s business model and regulatory activities.