Regulatory Disclaimer
MIFIDPRU Remuneration Disclosures
Introduction
Quadra Capital Partners LLP (“Quadra Capital” or the “Firm”) is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm is a London-based discretionary investment manager to professional clients and collective investment schemes. Quadra Capital is categorised as a BiPRU firm by the FCA for capital purposes and reports on a solo basis.
The Firm is a MiFIDPRU investment firm and the following disclosures have been made in accordance with the FCA’s MiFIDPRU remuneration requirements. This Remuneration Disclosure (the “Disclosure”) has been produced to satisfy the requirements of the MIFIDPRU 8 Disclosure requirements and provides a summary of the Firm’s qualitative and quantitative disclosures.
Remuneration Philosophy
Our remuneration philosophy and the objectives of our remuneration practices are consistent with and promote sound and effective risk management aligned with the business strategy, objectives and long-term interests of the Firm. The Firm’s remuneration arrangements are designed to:
- promote risk awareness and encourage responsible business conduct;
- reinforce positive cultures and the values of the Firm;
- encourage responsible business conduct;
- align the interests of staff with the long-term interests of the clients and the Firm commensurate with the Firm’s risk appetite;
- avoid conflicts of interests; and
- offer reasonable and competitive remuneration to attract and retain high calibre employees.
Given the nature and small size of our business, remuneration for all employees is set by the members of the firm. The firm formally reviews the performance of all employees and based thereon determines each employees overall level of remuneration and the split of that between base salary, bonus, etc. in compliance with the FCA Rules on remuneration.
Given that the Firm has only one business area, fund management, all remuneration disclosed in our audited financial statements is from this business area.
The Firm has defined “Code Staff” to be the Firm’s current senior management. The aggregate level of remuneration earned by the staff is disclosed in our audited financial statements.
Components of Remuneration
The Firm categorises all remuneration as either fixed or variable remuneration based on the ‘quality’ and ‘purpose’ of the remuneration.
The Firm pays fixed and variable remuneration in a balanced way with the fixed component representing a sufficiently high proportion of the total remuneration that enables the Firm’s Policy to work flexibly and includes the possibility of the Firm paying no variable remuneration.
Fixed remuneration is remuneration that primarily reflects a staff member’s professional experience and organisational responsibility as defined in their job description and terms of employment; and is permanent, pre-determined, non-discretionary, non-revocable and not dependent on performance.
Variable remuneration is remuneration that is based on performance or, in exceptional cases, other conditions that reflects the long-term performance of the staff member as well as performance in excess of the staff member’s job description and terms of employment.
Fixed and variable remuneration: partners of llp
Certain payments received by individuals who are Partners of the Firm are to be treated in accordance with the following requirements:
- at the end of each year, the residual profits of a partnership or LLP are distributed among the partners or members. The level of ownership of each partner or member is reflected in the number of ownership shares they have. Residual profits are distributed according to the ownership shares, so are not linked to work or performance; therefore payments on this basis are not remuneration;
- a Partner or member may receive an amount fixed at the beginning of the year and subject only to the Firm making a profit. These are often called fixed profit shares. A partner or member usually takes drawings on it throughout the year, often monthly. If profits at year-end are insufficient, drawings may have to be paid back. Drawings on fixed profit shares are considered fixed remuneration;
- a partner or member may receive a discretionary share of the profit at the end of the year. These may be distributed to all partners or members but are usually dependent on the performance of the individual or their business unit. Awards may be at the discretion of the remuneration committee. payments made on this basis are considered variable remuneration.
Where a partner or member of a limited liability partnership works full-time for a firm the FCA would expect a reasonable portion of the partner’s or member’s profit share to be categorised as remuneration. Where a partner or member works part-time and receives less remuneration than a partner or member who works full-time, the FCA would expect a smaller proportion of the part-time partner or member’s profit share to be classed as remuneration.
Financial and non-financial assessment criteria
The Firm considers both financial and non-financial criteria when assessing individuals for the purposes of determining the amount of variable remuneration to pay.
Non-financial criteria form a significant part of the performance assessment process, override financial criteria, where appropriate, include metrics on conduct, which make up a substantial portion of the non-financial criteria and include how far the individual adheres to effective risk management and complies with relevant regulatory requirements.
Summary of significant changes
There have been no significant changes to the Firm’s Remuneration disclosure compared to the previous period.
TIMING OF DISCLOSURE
This disclosure is published annually on the date we publish our annual financial statements and is published in Companies House.
Additional information for Canadian Investors
An investment in the shares of the fund mentioned in this document is only available to an investor who is: (a) an “accredited investor” within the meaning of National Instrument 45-106 – Prospectus Exemptions who is subscribing to the shares of the fund mentioned in this document and any subsequent shares as principal for its own account and not for the benefit of any other person; and (b) a “permitted client” within the meaning of National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations.
Securities legislation in certain provinces or territories of Canada may provide an investor with remedies for rescission or damages if this document contains a misrepresentation, provided that the remedies for rescission or damages are exercised by the investor within the time limit prescribed by the securities legislation of the investor’s province or territory. The investor should refer to any applicable provisions of the securities legislation of the investor’s province or territory for particulars of these rights or consult with a legal advisor.
QCPF – Environmental Criteria
Quadra Capital Partners France has a non-independent consulting activity.
Thus, it may receive retrocession from the funds managers that Quadra selected for its customers.
These retrocessions do not affect its analysis of these funds’ features and its ability to report on them, the strengths as the risks, in a full transparency to its clients and in their best interest.