MIFIDPRU Disclosure Statement
20 January 2025
Introduction
The Financial Conduct Authority (“FCA” or “regulator”) in its Prudential sourcebook for MiFID Investment Firms (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Robocap. In particular, Chapter 8 of MIFIDPRU (“MIFIDPRU 8” or the “public disclosures requirements”) sets out public disclosure obligations with which the Firm must comply, further to those prudential obligations.
Robocap is classified under MIFIDPRU as a small and non-interconnected investment firm (“SNI MIFIDPRU investment firm”). As such, MIFIDPRU 8 requires Robocap to disclose information regarding the Firm’s remuneration policy and practices.
The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture, and to assist stakeholders in making more informed decisions about their relationship with the Firm.
This document has been prepared by Robocap in accordance with the requirements of MIFIDPRU 8 and is verified by the management committee. The document will be updated following completion of the 2024 financial statements in 2025.
Remuneration Policy and Practices
As an SNI MIFIDPRU investment firm, Robocap is subject to the basic requirements of the MIFIDPRU Remuneration code.
The purpose of the requirements on remuneration are to:
• Promote effective risk management in the long-term interests of the Firm and its clients;
• Ensure alignment between risk and individual reward;
• Support positive behaviours and healthy firm cultures; and
• Discourage behaviours that can lead to misconduct and poor customer outcomes.
The objective of Robocap’s remuneration policies and practices are to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients.
In addition, Robocap recognises that remuneration is a key component in how the Firm attracts, motivates and retains quality staff and sustains consistently high levels of performance, productivity and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and greatest competitive advantage.
Robocap is committed to excellence, teamwork, ethical behaviour and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude and results.
Characteristics of the remuneration policy and practices
Remuneration at Robocap is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration are paid on a discretionary basis and take into consideration the Firm’s financial performance as well as the financial and non-financial performance of the individual in contributing to the Firm’s success. All staff members are eligible to receive variable remuneration.
The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.
Governance and Oversight
The management committee is responsible for setting and overseeing the implementation of Robocap’s remuneration policy and practices. In order to fulfil its responsibilities, the management committee:
• Is appropriately staffed to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital and liquidity;
• Prepares decisions regarding remuneration, including decisions which have implications for the risk and risk management of the Firm;
• Ensures that the remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors and other stakeholders in the Firm; and
• Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values and interests of the Firm and of its clients.
Robocap’s remuneration policy and practices are reviewed annually by the management committee.
Quantitative Remuneration Disclosures
1. Total Remuneration Paid to staff:
For the financial year 2023, the total amount of remuneration awarded to all staff was £465,834, of which £375,834 comprised the fixed component of remuneration, and £90,000 comprised the variable component. For these purposes, ‘staff’ is defined broadly, and includes, for example, employees of the Firm itself, directors, and secondees.
2. Variable remuneration:
Includes bonuses. The firm’s variable remuneration is performance-based and aligned with risk management practices.
3. Deferred Remuneration:
There is no deferred remuneration. However, a proportion of variable remuneration is required to be invested into the Robocap UCITS Fund to ensure alignment with long-term performance and risk mitigation.
4. Performance Adjustments:
During the period, no performance adjustments were made.
5. Confirmation:
The firm confirms that its remuneration policies comply with the requirements of MIFIDPRU 8 and are consistent with sound risk management practices.