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MIFIDPRU 8.6 Disclosure

Scope and purpose

This disclosure relates to GMT Communications Partners LLP (the “LLP”), which is classified as a small and non-interconnected (SNI) MIFIDPRU Investment Firm and is therefore required under MIFIDPRU 8.6 (“the disclosure”) 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 LLP’s activities.

Frequency of disclosure

Unless otherwise stated, all figures are as at 31 December 2022, the LLP's financial year end, in accordance with the rules set out in chapter 8 of MIFIDPRU. The disclosure is made public annually concurrently with the Annual Report and Accounts in accordance with regulatory guidelines.

Approach to remuneration

Base salaries are pre-determined, non-revocable compensation paid to individuals throughout the year, irrespective of the LLP’s or individual performance. Base salaries and benefits constitute a significant proportion of the LLP’s total remuneration. This fixed element is based on the professional experience and responsibility of the individual within the LLP.

The LLP may, at its complete discretion, award bonuses which are based on individual performance as well as the LLP’s underlying profitability. The bonus does not form part of individual’s contractual remuneration. The size of the bonus pool is linked to the overall performance of the LLP. The bonus 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 LLP considers both financial and non-financial metrics.

To enhance the alignment of staff performance with the asset performance of funds being managed by the LLP, and to reduce risk taking, certain investment professionals are invited to join the carried interest scheme (“CI Scheme”). The CI Scheme is linked to performance of the funds being managed by the LLP, and is achieved based on agreed benchmarks with investors. The individuals who are invited to join the CI Scheme, will also be expected to co-invest in the relevant fund, to further align the financial objectives of the individual and investors.

Objective of financial incentives

The objective of providing financial incentives is to attract and retain suitably qualified and motivated staff, promote behaviour that is aligned to the LLP’s long-term interests, strategic objectives, and ethical standards. Financial incentives are used to reward individual performance, subject to sufficient liquidity, overall profitability and regulatory capital being available within the LLP.

Governance and decision-making procedures

The LLP is required to implement and maintain remuneration policies, procedures and practices for all employees 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.

The remuneration practices and policies are intended to:

  • promote sound risk management practices in alignment with the LLP’s risk management principles;
  • discourage risk taking that is inconsistent with the LLP’s risk appetite or risk management policies and principles;
  • control fixed costs by ensuring that remuneration expense varies according to profitability and does not place undue constraints on the LLP’s ability to maintain its capital base;
  • link remuneration to the LLP’s financial and operational performance as well as individual performance;
  • promote a positive culture towards risk management and compliance.

The remuneration practices and policies are intended to support the LLP’s business strategy, long term interests and values, and to ensure that risk taking does not exceed the LLP’s level of risk. Periodic reviews ensure that remuneration at the individual level is not unreasonable or disproportionate to the amount, nature, quality, and scope of the work performed. The remuneration policy outlines the criteria used to assess the performance of the LLP and of individual staff members. The LLP’s performance is assessed against its overall financial performance and employee retention rates. In assessing the performance of individual staff members, the LLP considers financial and non-financial criteria. Non-financial criteria includes:

  1. performance in line with firm strategy or values;
  2. adherence to the firm’s risk management and compliance policies; and
  3. achieving objectives as set in the previous year’s annual appraisal.

During the year fixed remuneration was paid of 2023 £212k (2022:£209k), and variable remuneration of 2023 £1,030k (2022:£1,155k).

Diversity Statement

At GMT Communications Partners LLP, we are committed to providing equal employment opportunities and treatment for all candidates and employees. We are determined to create a work environment free from discrimination. Most importantly, we pride ourselves on our culture, where differences are valued at all levels of the organisation. We believe diversity of thought and background drives innovation and our holistic approach to recruiting allows us to create a diverse and inclusive network of employees across the entirety of the business.

Any form of discriminatory practice or behaviour is not tolerated, and we aim to ensure that all employees, candidates, clients, customers, suppliers and visitors are not treated less favourably, victimised or harassed. We are dedicated to making reasonable adjustments for all candidates where possible throughout the application process to ensure fairness and standardisation.